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Kennedy,Jenks Consultants Section 1: Introduction This Preliminary Work Plan for Evaluation of Nitrogen in Groundwater (Work Plan) has been prepared by Kennedy/Jenks Consultants, Inc. (Kennedy/Jenks) on behalf of the Musco Family Olive Company (Musco). The Work Plan is submitted in partial fulfillment of Provision No. 1.b. of Waste Discharge Requirements Order No. R5-2010-0025 issued to Musco by the Regional Water Quality Control Board, Central Valley Region (RWQCB) on 18 March 2010. 1.1 General Background The Musco olive processing facility is located at 17950 Via Nicolo Road in Tracy, California. Musco has operated at this location since 1983. The facility and associated land application areas are referred to as the "Site"for the purposes of this Work Plan. The Site encompasses approximately 280 acres of property in the southwest quarter of Section 34, Township 2 South, Range 4 East and in the northeast quarter of Section 4, Township 3 South, Range 4 East. The location of the Site is shown on Figure 1. Management of process wastewater at the facility is currently regulated under separate Waste Discharge Requirements Orders (WDRs) issued to Musco by the RWQCB. WDR No. R5-2005-0024 regulates and specifies required monitoring for the surface impoundments (Title 27 ponds), to which the more concentrated wastewaters and spent brine solutions are discharged. WDR No. R5-2010-0025 (the Order) regulates application of process wastewater to Musco's onsite land application system. In addition to requirements for ongoing monitoring and reporting, the Order specifies that Musco perform several additional technical evaluations. In particular Provision No. 1.b. requires: "By 30 July 2010, the Discharger shall submit a Workplan for Supplemental Evaluation of Nitrogen in Groundwater. The workplan shall describe existing site conditions and the known distribution of nitrogen in groundwater and provide a detailed scope of work for assessing the nature and extent of nitrogen in groundwater at the site and in background wells, and the potential for preferential waste constituent migration pathways within the LAAs and on-site tailwater drainages. The primary purposes of the study is to identify whether past operational practices have caused exceedance of water quality objectives; the mechanism(s)that caused the pollution; whether current treatment and control practices are adequate to prevent continued pollution, and whether a regional source(s) of nitrate is entering the Site from the southwest. The work plan shall describe all proposed investigative methods including, but not limited to, additional groundwater sampling locations (whether temporary or permanent), analytical testing, and data analysis." In response to requirements and responsibilities associated with its onsite wastewater management activities, Musco has characterized soil and groundwater in several areas of the Site. The history of subsurface characterization activities at the Site and the resulting understand of local geology, hydrogeology and groundwater quality have been presented by Musco in prior documents and are not repeated in this Work Plan. At this time, there are a total of forty groundwater monitoring wells associated with the Site. Eleven of these wells are currently dry and are monitored for moisture. As allowed by the Preliminary Work Plan for Evaluation of Nitrogen in Groundwater Page 1 Musco Family Olive Company, Tracy, California g:4�Wmin4nbWNM104,00_musrooNe100+pip Itq x Ohba dw