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Musco Family Olive Comp -4- 4 May 2012 <br /> Conclusion and Request for a Report <br /> Board staff is very concerned that the small amounts of wastewater reported in the sumps prior <br /> to the testing could indicate an on-going leak in the upper liners, given the limited ability of the <br /> LCRSs to convey water to the sumps. Staff's concern is further heightened by the occurrence of <br /> -saline water in lysimeter LY-1 8, where no water samples were obtained in the previous 25 <br /> years. <br /> Based on the LCRS test results and lysimeter results, Board staff has reasonably concluded <br /> that the LCRS beneath Pond A has failed. This is a violation of Discharge Specification B.13 of <br /> the WDRs. For Pond B, Board staff concludes that the LCRS may be operational, but that the <br /> pools of water found in the header pipes shows that the LCRS is unable to "prevent hydraulic <br /> head on the underlying liner at any time" as required by Discharge Specification B.13 of the <br /> WDRs. This failure is also a violation of the WDRs. <br /> In response, please submit a report by 15 June 2012 with a work plan and schedule to bring <br /> Pond A and Pond B into compliance with the WDRs and Title 27. Options to bring the ponds <br /> into compliance include, but are not limited to, reconstructing the ponds, reducing the volume of <br /> high strength wastewater generated so that one or both ponds can be closed, or trucking the <br /> high strength wastewater off-site. If Musco takes one or both ponds out of service during <br /> construction work, Musco should describe how it will manage the high-strength wastewater <br /> currently discharged to the ponds. The work plan should include a plan to assess whether <br /> wastewater has been released from the units into the subgrade soils. <br /> Board staff will be available to meet with Musco prior to this date to discuss the test results and <br /> corrective actions. The Monitoring and Reporting Checklist is attached. If you have questions or <br /> would like to schedule a meeting please call Todd Del Frate at 916-464-4737. <br /> WENDY S. WYELS, Supervisor <br /> Compliance and Enforcement Section <br /> Enclosure: Monitoring and Reporting Checklist <br /> cc: Robert McClellum, San Joaquin County Environmental Health <br /> Donna Heran, San Joaquin County Environmental Health Department, Stockton <br /> Michael Campos, Stoel Rives, Sacramento <br /> Gary Carlton, Kennedy/Jenks, Rancho Cordova <br /> Meredith Durant, Kennedy/Jenks, San Francisco <br /> Paul Harpainter, Tracy <br /> CIWQS VID#920596 <br />