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-14*4 California Wgional Water Quality Co Board <br /> Central Valley Region <br /> Robert Schneider,Chair 0 <br /> Linda S.AdamsArnold <br /> Sacramento I Main Office <br /> Secretaryfor Schwarzenegger <br /> Environmental 11020 Sun Center Drive#200,Rancho Cordova,California 95670-6114 Governor <br /> Protection Phone(916)464-3291 -FAX(916)4644645 <br /> http://www.waterboards.ca.gov/centralvalley <br /> Rol EC��I Y EE--`17 ED) <br /> 15 June 2006 JUN 1 9 ?006 <br /> ENVIROMA'-N I- HEALTH <br /> Dennis Leikam PERVIII/SERVICES <br /> Musco Family Olive Company <br /> 17950 Via Nicolo <br /> Tracy, California 95377 <br /> REVIEW AND COMMENT: CLASS 11 SURFACE IMPOUNDMENTS EVALUATION, MUSCO <br /> FAMILY OLIVE COMPANY, TRACY, FACILITY NO. 5B392059001 <br /> Board staff has reviewed the 29 July 2005 Class 11 Surface Impoundment Evaluation prepared <br /> by Kennedy/Jenks Consultants for the Musco Family Olive Company. The purpose of the <br /> evaluation was to provide an alternative method to test the integrity of the Class 11 Surface <br /> Impoundments and functionality of the Leachate Concentrate Recovery System (LCRS) <br /> installed as part of the Class 11 Surface Impoundments. <br /> In the letter dated 29 July 2005 Kennedy/Jenks reviewed the available information for the <br /> operation of the Class 11 Surface Impoundments and no written procedures were supplied to <br /> Musco for testing the LCRS. Kennedy/Jenks indicates there is some degree of risk associated <br /> with introducing water into the area beneath the impoundment liner(s). Board staff has the <br /> following comments. <br /> • It is unclear and the 29 July 2005 letter does not sufficiently explain what the risks are <br /> associated with testing the LCRS using water. Please explain your concern with <br /> introducing water into the area beneath the impoundment liner(s). Provide justification <br /> for not testing the LCRS using this method. <br /> • If testing the LCRS is deemed risky when introducing water, please provide a review of <br /> standard industry practice used to test LCRS that could replace water as the medium of <br /> choice. The review should include potential risks to the liner(s) associated with the use <br /> of other mediums. <br /> • Show in greater detail how the current test method is structured. Please include a <br /> figure that shows Pond details including pressure transducer location and depth, and <br /> include a proposed schedule of testing. As required by Waste Discharge Requirements <br /> (WDRs) No. R5-2005-0024, the LCRS shall be tested annually to demonstrate <br /> operation in conformance with WDR requirements. Results of these tests shall be <br /> reported to the Board and shall include comparison with earlier tests made under <br /> comparable conditions. <br /> California Environmental Protection Agency <br /> co Recycled Paper <br />