SITE INFORMATION AND CORRESPONDENCE

Home Browse Search

California Regional Water Quality Control Board \J Central Valley Region y — Robert Schneider,Chair Terry Tamminen Fresno Branch Office Arnold Schwarzenegger Secreiaryfor Intenne[Address: http://v .svacb.ca.gov/—mgcb5 Governor Environmental 1685 E Street,Fresno,California 93706-2020 Protection Phone(559)445-5116•FAX(559)445-5910 TO: Bert E.Van Voris";`RCE/`No. 24105 FROM: Jo Anne Kipps,RCE No. 49278 Supervising Engineer Senior Engineer DATE: 28 April 2004 SIGNATURE: SUBJECT: WASTEWATER SEEPAGE FROM MUSCO'S 84-MG RESERVOIR I reviewed Mr. Ben Hall's 7 April 2004 letter regarding the tailwater return system; Hall's 19 April 2004 letter regarding my recent telephone conversation with Mr. Ryan Olsen of Kleinfelder, Inc.; Summary of Testing and Observation Process Water Storage Reservoir, Musco Olive Products, San Joaquin County, dated 5 April 2004,prepared and certified by Ryan J. Olsen (RCE No. 64998) and Ron Heinen(RGE No. 388) of Kleinfelder, Inc.;Project Manual for the New Retention Pond of Musco Olive Products Inc. Tracy, California Project CA 2012-50 Site Preparation Work(Project Manual) dated February 2001 and prepared by FOODPRO INTERNATIONAL, INC.; and "as built" construction specifications for the reservoir, dated August 2003 and received 7 April 2004, certified by Richard G. Stratton, Jr. (RCE No. 37261). Musco submitted these documents after several verbal requests by staff for the report required by Task 16 of Revised Time Schedule Order No. R5-2002-0014-ROl (TSO). The TSO describes this task as follows: By 15 August 2002,the Discharger shall submit a report showing that the pond and tailwater system have been fully constructed and are operational. The report shall also describe the pond construction details and show that a liner, adequate to prevent the stored wastewater from impacting the groundwater, has been installed. The penalty shall be $5,000 for each day after 15 August 2002 in which the pond and/or tailwater system are not operational. In his 7 April letter, Hall cites several documents referencing the tailwater return system and states, "I am confident attesting to the fact that the tailwater system was complete and operational by July 15, 2002." He further explains that what little tailwater was generated during the summer months prior to the system's completion would have been returned to the 1-million gallon pond [and not discharged to surface water drainages]. Until evidence is presented that indicates otherwise (i.e., the findings of an upcoming field inspection by Amy Simpson to verify the adequacy of the tailwater system), I concur with Hall's assessment that the tailwater system was functional prior to the 15 August 2002 deadline specified in the TSO. Unfortunately, however, the Kleinfelder report and construction specifications do not certify the installation of a liner that complies with the directive of Task 16 (i.e., "adequate to prevent the stored wastewater from impacting the groundwater"). Section 02276 of the Project Manual describes the construction of a clay liner system consisting of a 7-inch-thick bottom clay layer, a 5-inch-thick upper clay layer, plastic wanting sheets, and a 6-inch-thick protective top layer of cohesive soils. The Project Manual identifies the clay liner's California Environmental Protection Agency Cd Recycled Paper