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California Regional Water Quality Control BoardC(I QW; Central Valley Region Robert Schneider, chair Winston H.Hickox Gray Davis Secretaryfor Sacramento Main Office Governor Environmental Internet Address: http://www.swrcb.ca.gov/rwgcb5 Protection 3443 Routier Road,Suite A,Sacramento,California 95827-3003 Phone(916)255-3000•FAX(916)255-3015 +�- f - _ 24 October 2003 `4 Paul Franzia Barrel Ten Quarter Circle Land Company 6342 Bystrum Road Ceres, CA 95307 ,,y INCOMPLETE VADOSE ZONE MONITORING WORK PLAN, BARREL TEN WINERY, ESCALON, SANJOAQUIN COUNTY I have reviewed the 21 October 2003 Vadose Zone Monitoring Work Plan addendum,prepared by Kennedy/Jenks Consultants. The addendum was submitted in response to the Regional Board's s 14 October 2003 Conditional Approval of the 1 October 2003 work plan. The work plan was prepared in response to Requirement No. 8 of Cease and Desist Order No. R5-2003-00125. Please clarify the following items in the addendum: Groundwater Well Installation Portion of the Work Plan The response to Item 1 does not clarify how the wells that will be installed on the east side of the land application areas will not be impacted by past wastewater application. Additionally, the locations of the off-site contaminant source areas are not identified so evaluation of the well placement by Regional Board staff is impossible. Please identify the locations of the off-site potential contaminant source areas. The response to Item 2 is not clear: "This sampling effort is intended to establish subsurface physical conditions and background chemical properties such as cation exchange capacity(CEC). The current chemistry information is not critical for this sampling objective. The analysis of soil samples from soil boring will show the constituents in the soil during excavation." Please clarify the statement. Vadose Zone Monitoring Portion of the Work Plan The response to Item 1 states that most of the wastewater will be discharged to Land Application Area (LAA)No. 5 but does not address the water balance presented as Table 2 in the 1 October 2003 Work Plan. Table 2 clearly indicates all the available land application areas will receive wastewater. A new water balance that supports the concept of limiting wastewater application must be submitted to support the proposed approach. The response to Item 3 states the sampling frequency will be established by the timing of process water applications to LAA No. 5. This seems to be in conflict with the response to Item No. 1 described California Environmental Protection Agency Recycled Paper The energy challenge facing California is real. Every Californian needs to take immediate action to reduce energy consumption. For a list of simple ways you can reduce demand and cut your energy costs,see our Web-site at ham://w-ww.swrcb.ca.gov/rwgcb5