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a •` STATE OF CALIFORNIA PETE WILSON, Governor <br /> CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD <br /> CENTRAL VALLEY REGION — <br /> 3443 Routier Road, Suite A ° <br /> Sacramento, CA 95827-0981, <br /> PHONE: (916) 361-5600 <br /> FAX (916)361-5686 <br /> rNtmt is <br /> 29 April 1992 <br /> APR 3 0 1992 <br /> ENVIR0NPAENV1,q[_ HE ?LiH <br /> Ms. Gail Holmes PER'^�11T%SEI"VXES <br /> Condor Earth Technologies Inc. <br /> P.O. Box 3448 <br /> Turlock, CA 95381 <br /> REVIEW OF PUREGRO/BREA AG WORKPLAN <br /> Thank you for submitting the 21 April groundwater investigation workplan for <br /> PureGro/Brea Ag in Stockton. After reviewing the workplan, I have the <br /> following comments: <br /> Section 2. 1 : Hvdrogeologv <br /> While the regional groundwater gradient may be to the N-NW, Regional <br /> Board investigations at nearby facilities have shown differing <br /> gradients. For example, at Marley Cooling Tower, the shallow <br /> groundwater is moving to the S-SW. At Kearney KPF, the gradient is <br /> slightly W-SW. An underground tank investigation on E. Fremont Street <br /> found a gradient slightly N one quarter, then to the SW the next <br /> quarter. <br /> Section 3.1 : Historical Review <br /> Why are you going to complete a historical review of groundwater <br /> characteristics after you have decided on the placement of monitoring <br /> wells? It seems like this review should be used to help decide on the <br /> placement. <br /> Section 3.2: Location of Monitoring Wells <br /> As I understand the workplan, you propose to install three wells now, <br /> and then up to three more wells at a later date. Does PureGro agree to <br /> this? In addition to assessing the water quality impact from the oil- <br /> water separator and dry wells, the monitoring wells should be placed to <br /> assess any impact from the former pond (in the NW corner of the yard) , <br /> and from the former location of the above ground fumigant tanks (south <br /> of the old pond) . This impact may be assessed with either the initial <br /> three wells, or with a subsequent set of wells. <br /> Section 3.3: Drilling and Soil Samples <br /> Who will decide if the extra soil samples will be analyzed? What <br /> criteria will be used? <br /> Section 3.4: Monitor Well Construction <br /> When will you determine the amount of seasonal groundwater fluctuation <br /> (and therefore the screen length for the wells)? Will you run this by <br /> the Regional Board for approval? <br />