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Benjamin Hall - 3 - Class 3 - Class II Surface Impoundments Musco Olive Products & Studley Company Facility ID 5B392059001 Discharge Specification 19, states: "Solids which accumulate in the surface impoundments shall be periodically removed to maintain minimum freeboard requirements and to maintain sufficient capacity for surface impoundment leachate and for the discharge of wastes. Prior to removal of these solids, sufficient samples shall be taken for their characterization and classification pursuant to Article 2 of Chapter 15. The rationale for the sampling protocol used, the results of this sampling, and a rationale for classification of the solids shall be submitted to Board staff for review." Based on these requirements and conditions, we require Musco to perforni a LCRS inspection to verify whether the system is functioning according to its design. We also request that the ponds be cleaned of sediment and surveyed for leak detection. As discussed, several companies perform leak detection surveys for surface impoundments. In fact, as a reference, the San Joaquin County Solid Waste Division is running a leak detection test at the new expansion of their liner at the North County Landfill the week of September 22"d. They also contracted the same leak detection survey at the Foothill Landfill for the same purpose. These types of surveys are becoming common in the environmental business to ensure that liners are performing accordingly. Please submit your scope of work and schedule to comply with this request in the 1 October 2003 letter as above. 4. W-21985 has a 5 foot screen. The fact that the well has been dry for so many years is � ) only probably due to the screened interval. Normally a 15-20 foot screen is installed with 5 feet above the highest hydrostatic level to ensure that seasonal fluctuations are accounted for during quarterly sampling. In this regard,we request Musco install a new well adjacent to W-2. Additional wells may also be required around the surface impoundments to ensure that all water bearing zones are monitored upgradient, side gradient, and downgradient, as applicable. These activities should be addressed and included in the workplan for further investigations at the site, which must be described in the 1 October 2003 letter. 5. Now that there is groundwater monitoring occurring at the site,Musco shall comply with the Standard Provisions and Reporting Requirements, dated September 1993,which are incorporated by reference in Order No. 96-075. The Standard Provisions and Reporting Requirements contain important provisions and requirements with which Musco must comply. A violation of any of the Standard Provisions and Reporting Requirements is a violation of these waste discharge requirements. At a minimum, the Standard Provisions and Monitoring Requirements 1993 require the following information be submitted.