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Mr. Benjamin Hall • 5 - 15 October 2004 <br /> ` Musco Family Olive Company <br /> the importance of establishing that the reservoir is essentially impermeable. Staff must eventually <br /> propose that the Regional Board require termination of use or complete lining of the reservoir unless <br /> Musco prior to such Regional Board consideration provides indisputable evidence either (1)that the <br /> reservoir does not leak enough waste to degrade groundwater or (2) that the quality of impounded <br /> wastewater and sludges is such that they will not degrade groundwater even if the reservoir leaks <br /> significantly. Due to the complexities of the site and practical limitations imposed by the situation, the <br /> only means available to obtain indisputable results about effectiveness of containment would be an <br /> isotope or tracer dye study of sufficient duration. Such data could be readily obtained from the results of <br /> a long-term isotope or tracer dye study. In such a study, an isotope or tracer dye (e.g.,rhodamine or <br /> fluorescein) is introduced to the impounded wastewater and dye concentrations are monitored in the <br /> impounded wastewater, blanket drain discharge and groundwater monitoring wells. Whether additional <br /> time necessary to conduct such a study would be in the public interest is questionable. Should Musco <br /> wish to perform such a study, we recommend it submit to this office a work plan and implementation <br /> schedule for Regional Board staff review. Authorization of the time required may be a matter the <br /> Regional Board itself would need to consider as part of a future action. <br /> If you have y ues 'ons garding this matter,please contact Amy Simpson at (559)445-6187. <br /> R E. N ORIS <br /> Supervising Engineer <br /> RCE No. 24105 <br /> cc: Ms. Kim Schwab, Regional Water Quality Control Board, Sacramento <br /> Ms. Teresa Geimer, California Department of Water Resources, Sacramento <br /> Ms. Charyce Taylor, California Department of Water Resources,Fresno <br /> Mr. Mike Huggins, San Joaquin County Environmental Health Department, Stockto <br /> Mr. David Irey, Esq., San Joaquin County District Attorney, Stockton <br /> Mr. Nick Musco, Studley Company, Tracy <br /> Mr. Michael Campos, Esq., Stoel Rives LLP, Sacramento <br /> Mr. Joseph Zilles, Kleinfelder, 2825 E. Myrtle Street, Stockton, CA 95205-4794 <br /> Mr. Bill Jennings, DeltaKeeper, 3536 Rainer Avenue, Stockton, CA, 95204 <br /> Mr. Paul Harpainter, Tracy - <br /> V:\Municipal\Projects\Outgoing.04-05\Tech Rpt Reviewtams 84mgResSeepage.d0c <br /> N15/E/MUSCO FAMILY OLIVE COMPANY/W WT&LAND DISPOSAL FACILITY/513392059002 <br />