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, <br /> California Regional Water Quality Control Board <br /> QW; <br /> . Central Valley Region <br /> Robert Schneider,Chair <br /> Terry Ta?yfor Fresno Branch Office Arnold Schwarzenegger <br /> EnviSecron enta Internet Address: http://w .swreb.ca.gov/—rwgcb5 Govemor <br /> Environmental l 1685 E Street,Fresno,California 93706 <br /> Protection Phone(559)445-5116•FAX(559)445-5910 IL <br /> r <br /> ) <br /> 15 October 2004 L <br /> Mr. Ben Hall i 8 204 <br /> Musco Family Olive Company <br /> 17950 Via Nicolo ENV�RuiviVl��� ,J CESS <br /> Tracy, CA 95376 <br /> RESPONSE TO 28 APRIL 2004 NOV, MUSCO FAMILY OLIVE COMPANY, SAN JOAQUIN <br /> COUNTY <br /> Your letter of 28 May 2004, and a technical letter report dated 3 June 2004 and received here on 10 June <br /> 2004 prepared by Ms. Paula Hansen and Mr. Joseph A. Drago (RCE No. 27822) of Kennedy/Jenks <br /> Consultants, respond to a 28 April 2004 Notice of Violation (NOV)to Musco Family Olive Company <br /> and the Studley Company(hereafter jointly referred to as Musco). Though neither submittal is certified <br /> as required by Standard Provisions B.3 of Waste Discharge Requirements Order No. R5-2002-0148 <br /> (WDRs), we have accepted them. Our review of the response warrants additional comment. <br /> Notice of Violation <br /> The 28 April 2004 NOV cited Musco for being in violation of Discharge Prohibition A.1 of the WDRs and <br /> of Task 16 of Revised Time Schedule Order No. R5-2002-0014-ROI (TSO). Prohibition A.1 prohibits the <br /> direct or indirect discharge of wastes to surface waters or surface water drainage courses. Task 16 requires <br /> the submittal by 15 August 2002 of a report showing, in part,that a liner adequate to prevent the stored <br /> wastewater from impacting groundwater has been installed. The NOV enclosed a Regional Board staff <br /> memorandum prepared by Ms. Jo Anne Kipps (RCE No. 49278) (hereafter"memorandum") containing an <br /> analysis of water quality data that concluded the discharge from the dam's blanket drain to the surface <br /> water drainage is partially composed of waste constituents from impounded wastewater and, as such, <br /> constituted a violation of Discharge Prohibition A.I. The memorandum also described staff analysis of <br /> technical evidence that led to a conclusion that release of waste constituents from impounded wastewater <br /> has impacted groundwater. The NOV directed Musco, pursuant to California Water Code Section 13267, <br /> to (1) submit by 28 May 2004 a technical report describing a work plan and implementation schedule for <br /> installing the necessary piping and appurtenances that will effectively and reliably preclude the discharge <br /> of seepage from the dam's blanket drain to the surface water drainage course and (2) immediately <br /> commence performing additional specified monitoring of the blanket drain discharge, the spring upstream <br /> of the 84-mg reservoir, and groundwater, and to report this monitoring data in Musco's monthly self- <br /> monitoring reports. <br /> Proposed Return System <br /> Your letter briefly describes a return system consisting of a 3-foot by 3-foot by 6-foot deep epoxy-lined <br /> concrete sump for collecting and returning the blanket drain discharge to the 84-mg reservoir. You did <br /> not provide the requested implementation schedule,requesting instead that construction be held in <br /> abeyance until Musco's consultants complete their analysis of the source of the blanket drain discharge. <br /> California Environmental Protection Agency <br /> 0 Recycled Paper <br />