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California Regional Water Quality Control Board , vCentral Valley Region ' 1 Robert Schneider,Chair Winston H. llickos 02 eco °2 PM WT �fDavis Secretaryfor Sacramento Main Office irl'oo, Environntcnml Intemet Address: http://w .swreb.ca.gov/mgcb5 Protection 3443 Routier Road,Suite A,Sacmmento,California 95827-3003 Phone(916)255-3000•FAX(916)255.3015 19 September 2003 Benjamin Hall Nick Musco Musco Olive Products Studley Company 17950 Via Nicolo 17950 Via Nicolo Tracy, CA 95376 Tracy, CA 95376 TITLE 27 MONITORING REPORT REVIEW, CLASS II SURFACE IMPOUNDMENTS, MUSCO OLIVE COMPANY, SAN JOAQUIN COUNTY, FACILITY#5B392059001 We have reviewed the monitoring reports for the Title 27 Class 11 Surface Impoundments at the Musco Olive facility in San Joaquin County. The reports include the Fourth Quarter 2001 report through Second Quarter 2003. They include the 2001 and 2002 Annual reports, as well. We have also referenced the Groundwater Monitoring Well Installation, Sampling and Analysis (April 2002) report. The two Class n surface impoundments are regulated under Title 27, California Code of Regulations, Division 2, Subdivision 1 (Title 27), Waste Discharge Requirements Order No. 96-075, Monitoring and Reporting Program (MRP), Standard Provisions and Monitoring Requirements 1993, and the Basin Plan'. According to our review of the subject reports, we find Musco is out of compliance with the WDRs, which include the Standard Provisions and Reporting Requirements 1993. Attached is a Checklist, which summarizes the status of the quarterly and annual monitoring reports. Please use this Checklist as a guide for formulating subsequent reports. Be aware that these are minimum requirements and that site specific WDRs may require more information in monitoring reports. There have been major changes occurring at this facility since the adoption of Order No. 96-075; therefore,we have forwarded a letter to Musco Olive, dated 11 September 2003,which requests submittal of a Report of Waste Discharge by 1 January 2004. The revised WDRs will be more specific in what is required by Musco to ensure compliance with Title 27 and the policies of the Regional Board. Now that there are groundwater monitoring wells in place and water quality data is being gathered, additional information is required that Musco should be including in their reports. The following comments reflect the major issues that must be addressed in subsequent reports: 1. All technical reports required herein that involve planning, investigation, evaluation, or design, or other work requiring interpretation and proper application of engineering or geologic sciences, shall be prepared by or under the direction of persons registered to practice in California pursuant to California Business and Professions Code sections 6735, 7835, and 7835.1. To demonstrate compliance with sections 415 and 3065 of Title 16, CCR, all technical reports must contain a statement of the qualifications of the responsible registered professional(s). As required by these Central Valley Water Quality Control Plan for the Sacramento and San Joaquin River Basins,Fourth Edition California Environmental Protection Agency 07 Recycled Paper 'Die 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.swrcb.ca.gov/mgcb5