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4 � <br /> California Regional Water Quality Control Board <br /> Central Valley Region (@ <br /> Steven T.Butler,Chair Gray Davis <br /> Winston R.Hickox <br /> Secretaryfor Sacramento Main Office Governor <br /> Environmental Internet Address: http://wvnv.swrcb.ca.gov/—mgcb5 <br /> Protection 3443 Routier Road,Suite A,Sacramento,California 95827-3003 <br /> Phone(916)255-3000•FAX(916)255-3015 t� <br /> C_: <br /> r-- <br /> N <br /> lil <br /> 25 July 2000 <br /> N <br /> Mr. Benjamin Hall Cn <br /> Musco Olive Products <br /> 17950 Via Nicolo <br /> Tracy, CA 95376 <br /> INCOMPLETE REPORT, MUSCO OLIVE PROD UCTS'1-MILLION GALLON POND <br /> MONITORING WELL WORKPLAN, SAN JOA QUIN COUNTY <br /> I have reviewed the 14 July 2000 "Musco Olive Products' 1-Million Gallon Pond Monitoring Well <br /> Workplan,"prepared by HDR. The report was submitted in response to a Regional Board request for a <br /> groundwater investigation workplan dated 15 May 2000. Because the workplan does not describe a plan <br /> to adequately investigate subsurface conditions at the one-million gallon storage pond(Pond No. 1), the <br /> workplan is incomplete and a revised workplan is required. After reviewing the workplan, I have the <br /> following comments: <br /> • The workplan states, "There has not been any evidence of leakage from the pond." There is <br /> substantial evidence that Pond No. 1 has overfilled as described in the 15 May 2000 Notice of <br /> Violation(NOV) and accompanying photograph log. Please provide further discussion on <br /> HDR's evaluation of the subsurface leakage conditions. <br /> • The Water Well Drillers Report(WWDR)provides information on the subsurface lithology in <br /> the area near Pond No. 1. The WWDR identifies numerous sand or gravel lenses less than 225 <br /> feet deep. Because the gravel pack in the fire protection well extends from depths of 50 to 607 <br /> feet, the well may act as a preferential conduit for groundwater to migrate to lower aquifers. <br /> • The fire protection well is drilled to a depth of 607 feet; information on the perforated interval <br /> was not included with the WWDR. Considering the gravel pack interval (50-607 ft. bgs), the <br /> lithology reported in the W WDR, and the depth to water in the fire protection well, saturated <br /> zones may be shallower than presented in the workplan. <br /> • The workplan states no groundwater degradation was observed in the fire protection well; <br /> however, the analytical data presented in Appendix C does not agree with that statement. The <br /> fire protection well analytical data, collected between the years 1982 and 1999, shows substantial <br /> concentration increases. The following percent increases were reported in Appendix C: specific <br /> conductance (20 percent), total dissolved solids (54 percent), sodium(94 percent), chloride (127 <br /> percent), and sulfate (131 percent). The cause for the increased concentrations maybe unknown, <br /> but staff does not agree with the workplan assertion that the data indicates no contamination. <br /> California Environmental Protection A2ency <br /> 0 Recycled Paper <br />