SITE INFORMATION AND CORRESPONDENCE

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Benjamin Hall _2 - Class _Class II Surface Impoundments Musco Olive Products & Studley Company Facility ID 5B392059001 laws, completed technical reports must bear the signature(s) and seal(s) of the registered professional(s) in a manner such that all work can be clearly attributed to the professional responsible for the work. 2. As discussed in a phone call with Benjamin Hall,Board staff regulating the surface impoundments has not been receiving technical documents relative to hydrogeologic, geochemical, and/or stratigraphic interpretations of the data by Musco. Mr. Hall stated that a list of documents would be sent to the Sacramento office so we may choose which ones we want to receive. At this point, all we have to work with is the 30 April 2002 Groundwater Monitoring and Installation Report and the quarterly/annual monitoring reports showing water quality data for W-2, MW-11 and MW-12. Nevertheless, the Annual reports should include any new sampling and analysis information that is related to water quality at the site based on WDRs/MRP. The Class Il surface impoundments are surrounded by W-2, MW-11, and MW-12. Based on the stratigraphy and water quality, it does not appear that these wells sample the same water bearing zones; therefore, they cannot be correlated with regards to which aquifer is upgradient or downgradient to the other since they appear to be different. Title 27, Section 20390 requires the establishment of Water Quality Protection Standards as part of the WDRs. Title 27, Section 20400 describes how Concentration Limits are developed. This information should be included in the Report of Waste Discharge referenced in the Regional Board's letter of 11 September 2003. Please be aware that a minimum of 8 samples should be used to perform non-statistical or statistical analysis for inorganic constituents for interwell or intrawell analysis. We request Musco provide an evaluation of W-2, MW-11, and MW-12 to determine whether these wells adequately monitor the first water bearing zone and any other water bearing zones below the surface impoundments in compliance with Title 27, Section 20425 for Detection Monitoring. Mr. Hall stated that Musco's consultants were currently working on this issue and that additional investigations were planned for the near future based on a new workplan. Please ensure that the issues related to the surface impoundments are addressed in this upcoming workplan for our review. We request that Musco submit a letter to the Regional Board by 1 October 2003 describing the scope of work of the workplan and when the plan will be submitted to the Regional Board. 3. Title 27, Section 20340(d) states, "Clogging—LCRSs shall be designed and operated to function without clogging through the scheduled closure of the Unit and during the post closure maintenance period. The systems shall be tested at least annually to demonstrate proper operation. The results of the tests shall be compared with earlier tests made under comparable conditions." The LCRSs for both surface impoundments has never produced liquid. We are concerned that the LCRSs are not functioning as they were designed. Secondly, you stated that the 40 mil hypolon liner system has a 20 year warranty. The surface impoundments were built in 1986 under the original WDR Order No. 86-074; therefore, the ponds are 17 years old. Order No. 96-075