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California Regional Water Quiaiity Conti®i Board ;% VIN <br /> Central l7alley Legion M k) <br /> Robert Schneider,Chair <br /> Winston H.Hickox Orae Davis <br /> Secretary for Sacramento Main Office Governor <br /> Environmental Internet Address: http://www.swreb.ca.gov/rwgcb5 <br /> Protection 3443 Routier Road,Suite A.Sacramento,California 95827-3003 <br /> Phone(916)255-3000•FAX(916)255-3015 <br /> VIA FACSIMILE <br /> 14 November 2003 <br /> : _--� <br /> F, ... <br /> Paul Franzia ' `� <br /> Barrel Ten Quarter Circle Land Company <br /> 6342 Bystnim Road ' 1. <br /> Ceres, CA 95307 <br /> REPORT REVIE TY, VAD OSE ZONE MONITORING WORKPLAN ADDEND UM, BARREL TEN <br /> WINERY, ESCAL ON, SAN JOA QUIN COUNTY <br /> I have reviewed the 12 November 2003 Vadose Zone Monitoring Work Plan Addendum,prepared by <br /> Kennedy/Jenks Consultants. The addendum was prepared in response to the Regional Board's <br /> 24 October 2003 Incomplete Vadose Zone Monitoring Work Plan correspondence. The 12 November <br /> 2003 addendum does not adequately address some of the Regional Board concerns about the proposed <br /> work. However, Barrel Ten may implement the workplan with the understanding that the investigation <br /> as proposed may result in ambiguous data being collected. Such ambiguous data may have significant <br /> implications when preparing the Report of Waste Discharge (RWD) that is due on 1 February 2005. The <br /> RWD is required by Item 12 of Cease and Desist (C&D) Order No. R5-2003-125. Staff has the <br /> following comments on the addendum: <br /> • Staff recognizes that installation of additional wells is not required by the C&D Order and that work <br /> is being performed voluntarily by Barrel Ten. Barrel Ten has stated that the purpose of the proposed <br /> wells is to further define upgradient water quality. As stated during staff's conference call with <br /> Barrel Ten on 3 November 2003, Barrel Ten is free to install the wells in the positions it desires, but <br /> staff will not consider the data acquired from these wells as "upgradient" or"background" values <br /> unless Barrel Ten can show that the wells are not impacted by the wastewater disposal at the land <br /> application areas. Better placement of wells could resolve that uncertainty. <br /> • Collection of soil samples from areas adjacent to the land application area may result in ambiguous <br /> data similar to the conditions described for the proposed wells. <br /> • Staff remains concerned that the wastewater application plan for the facility is not workable. For <br /> example, the 12 November 2003 describes a reduction of wastewater flow of 20-percent but expects <br /> to generally limit wastewater application to Basins 1 and 3,which constitute approximately 40- <br /> percent of the available land application area. Such an approach may overload the areas <br /> hydraulically, organically, and with dissolved solids. Furthermore, the addendum states, <br /> "...additional lysimeters can be installed, if necessary, in the other spreading basins." The purpose <br /> California Environmental Protection Agency <br /> Oa Recycled Paper <br /> The energy challenge facing California is real. Every Californian needs to take immediate action to reduce energy consumption. <br /> For a list of simple ways you can reduce demand and cut your energy costs,see our Web-site at http://www.sATcb.ca.gov/rwgcb5 <br />