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California Regional Water Quality Control Board ` Central Valley Region Robert Schneider Chair Winston H.Hickox ' Davis Secretaryfor Sacramento Main Office Gos ernor Environmental F� Internet Address: bttp://www.swreb.ca.gov/—rwqcb5 A * Protection j�- 3443 Routier Road,Suite A,Sacramento,California 95827-3003 Phone(916)255-3000•FAX(916)255-3015 8 March 2002 Mr. Benjamin Hall Mr. Nick Musco Musco Olive Products Studley Corporation �17950'tV_a�NicoIoy 17950 Via Nicolo Tracy, CA 95376 Tracy, CA 95376 REVIEW OF GROUNDWATER MONITORING WELL WORKPLAN, MUSCO OLIVE PRODUCTS, TRACY, SAN JOAQUIN COUNTY I have reviewed the 20 February 2002 Groundwater Monitoring Workplan, prepared by Kleinfelder, Inc. for Musco Olive Products that was submitted to the Regional Board on 25 February 2002. The report was prepared in response to Task No. 6 of the California Water Code (CWC) Section 13308 Time Schedule Order adopted by the Regional Board on 25 January 2002. I have the following comments about the report: • Section 4 of the report presents an implementation schedule. Please be aware that the Time Schedule Order requires submittal of the Groundwater Monitoring Well Installation Report by 1 May 2002. Failure to meet that deadline may lead to a penalty of$2,500 per day late. • Please make the following changes to the well locations presented on Plate 2: — Add a well downgradient of the 95 acre land application area. The well should be Iocated in the drainage in an area near the railroad track. — Move the well in the 35 acres of new irrigated pasture to the northeast, resulting in a more central monitoring location downgradient of the application area. • Please provide a description of the "cement based grout material," described in workplan Section 3.2. ,Note that this must be consistent with San Joaquin County Environmental Health Well Standards Section 13.12.3. • Appendix Section B-3.1 does not describe how the annular seal will be placed. Please describe seal placement method that is consistent with Part 11, Section 9F of the California Well Standards Bulletin 74-90. • Appendix Section B-3.1 describes the possibility of installing the filter pack by tremie pipe; however, SJCEH Well Standards Section 13.10.5 prohibits introduction of foreign substances to the filter pack and Section 13.10.6 requires use of a tremie pipe or equivalent for filter pack placement. California Environmental Protection Agency Recycled Paper The energy challenge facing California is real. Every Californian needs to take immediate action to reduce energy consuurptiou. For a list of simple ways you can reduce demand and cut your energy costs,see our Web-site at http://www.swreb.ca.gQv/rwgcb5