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S-,ATE OF CALIFORNIA -Environmental ProteTon Agency • PETE WILSON, Governor S CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD 4 CENTRAL VALLEY REGION 3443 Routier Road,Suite A acramento, CA 95827-3098 ONE: (916)255-3000 X: (916) 255-3015 a 12 October 1994 psmyq nrr4 1 1994 ENVIRONMcNTAL HEALTH Mr. Mark Geweke PERMIT/ Geweke Land Development and Marketing P.O. Box 1210 Lodi, CA 95241 REVISED MONITORING AND REPORTING PROGRAM, 16 SOUTH CHEROKEE LANE, LODI, SAN JOAQUIN COUNTY We have reviewed your comments on the draft Revised Monitoring and Reporting Program (RMRP), dated 9 September 1994, prepared and submitted by Geological Audit Services (GeoAudit). A second draft RMRP (attached) incorporates several changes recommended by GeoAudit. Additions to the RMRP are in italics and deletions in strike out. Note the following changes: • 1. In Table 1, all wells which contain enough water to allow proper sample collection protocol, shall be sampled. 2. In Table 1, ethylenedibromide and lead have been eliminated from monitoring in ground water. 3. In Table 2, monitoring of Purgeable Aromatic Organics and TPHg have been reduced from twice monthly to monthly. 4. In Table 3, barometric pressure has been eliminated from soil gas monitoring. 5. Soil sampling has been reduced from 3 borings around all inoculated wells (a total of 45 borings per quarter) to 6 borings per quarter. 6. In Table 4, Purgeable Halogenated Organics and lead have been eliminated from the soil sampling. 7. The monitoring frequency and constituents in Tables 2, 3, and 4, may be modified, at the Board's discretion, after several rounds of monitoring. You suggested additional modifications to the RMRP which we have not incorporated. Until data and information have been collected regarding the effects of the inoculation on the presence of bacteria and contaminant levels in soil and ground water, we believe that the number of monitoring points in Tables 2 and 3 must remain as shown in this draft RMRP. You recommended quarterly monitoring for bacteria in ground water. Three months is long enough for complete die-off to occur. The other monitoring methods may not be adequate to determine changes in the bacterial populations. In the RMRP, the wells chosen for monitoring in Table 2, include wells MW6, MW10, (upgradient wells) and MW13 (downgradient). MW6 and MW10 have been contaminated and it has not been demonstrated that the contamination moves upgradient. MW13 is the only well that has not