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California Regional Water Quality Control Board a �:- Central Valley Region Winston H.Hickox J Robert Schneider, Chair �"`""Secretary for Gray Davis Sacramento Main Office Governor Environmental Internet Address: http:/lwww,swrcb.ca.gov/rwgcb5 Protection 3443 Routier Road,Suite A,Sacramento,California 95827-3003 Phone(916)255-3000•FAX(916)255-3015 TO; Timothy R. O'Brien FROM: Kim A. Schwab Assoc. Engineering Geologist Assoc. Engineering Geologist Non-Chapter 15 Discharge to Land Waste Discharge to Land DATE: 1 March 2002 SIGNATURE: SUBJECT: GROUNDWATER MONITORING WORKPLAN, MONITORING WELL INSTALLATION, SAMPLING AND REPORT, MUSCO OLIVE PRODUCTS, INC AND THE STUDLEY COMPANY SANA JO QUIN COUNTY We have reviewed the subject document dated 20 February 2002, as prepared by Kleinfelder, Inc. The Workplan was partially prepared to address the Board's notice of violation letter dated 2 February 2002 with regards to the Class IT Surface Impoundments regulated under Waste Discharge Requirements (WDRs) Order No. 97-075 and Title 27, California Code of Regulations (Title 27), Division 2, Subdivision 1. We are concerned that the current groundwater monitoring system has not yielded enough water for sampling for an extended period of time, therefore we requested Musco provide additional groundwater monitoring pursuant to Title 27; §20415(b)(1)(B) Detection Monitoring Program. E We request the Discharger respond to the following comments, either in an addendum or revision to the Workplan: 1. Plate 2 shows a proposed groundwater well location on the north side of the surface impoundments. It has come to my attention that the domestic wastewater system is iri the vicinityof this proposed well location. Furthermore, during an inspection on 16 October 2001, irrigation of wastewater was occurring in the area immediately north of the surface impoundments. We are concerned that these two activities may have impacted groundwater quality in this area. Please provide detailed information with regards to the two above issues in order to justify this groundwater well location. If appropriate, propose an alternative location that meets the intent of the Detection Monitoring Program of Title 27, 2. Section 3.2 states that, "An experienced environmental engineer or geologist will log the soil borings." Title 27 20415(e)(2) requires all monitoring wells and all other borings (including but not limited to gas monitoring wells) drilled to satisfy the requirements of this division, be drilled by a licensed drilling contractor (or by a drilling crew under the direct supervision of the design engineer or engineering geologist), and shall be logged during drilling under the direct supervision California Environmental Protection Agency Ve* Recycled Paper The energy challenge facing California is real. Every Californian needs to take immediate action to reduce energy consumption. For a list of simple ways you can reduce demand and cut your energy costs,see our Web-site at http://www.swreb.ca.gov/rwgcb5 i