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Paul Franzia - 2 - 14 February 2006 <br /> The issue of establishing the background groundwater quality has been addressed in a number of <br /> documents, including the CDO. Staff believes background groundwater quality has been defined by <br /> Well No. MW-1. We are aware that Wells MW-6 and MW-7 have been installed but as stated in <br /> correspondence dated 14 October 2003, 24 October 2003, and 14 November 2003 (attached) data from <br /> the wells is ambiguous due to the close proximity of the land application areas and the potential for <br /> groundwater mounds to have impacted groundwater quality upgradient of the land application area. <br /> Adequate time has certainly been provided for you to better define groundwater quality; if you wish to <br /> demonstrate an off-site source is impacting the groundwater quality beneath your land application area <br /> you should initiate investigations. However, any work that is planned should be described in a <br /> workplan provided to staff for review. <br /> By 28 February 2006, please submit an Engineering Report, Report of Waste Discharge Addendum H <br /> that describes the improvements that will be implemented and the anticipated improvements to <br /> wastewater quality and groundwater quality protection. These improvements must be such that the <br /> resulting effluent will not impact background groundwater quality (approximately 475 mg/L of total <br /> dissolved solids). If not, staff will recommend that the facility be regulated under California Code of <br /> Regulations Title 27. <br /> If you have any questions on this information, or would like to schedule a meeting to discuss the issues <br /> identified in this letter, please telephone me at(916) 464-4616. <br /> TIMOTHY O'BRIEN <br /> Waste Discharge to Land Unit <br /> Enc: 14 October 2003, Conditional Approval of Vadose Zone and Groundwater Monitoring Workplan <br /> 24 October 2003, Incomplete Vadose Zone Monitoring Workplan <br /> 14 November 2003, Report Review Vadose Zone Monitoring Workplan <br /> cc: Mike Huggins, San Joaquin County Environmental Health Department, Stockton <br /> Robert Chrobak, P.E., Kennedy Jenks Consultants, San Francisco <br /> W ASIaBlObrienTlSan JoaquinlBaml Ten Escalon WineryT—ja 10 Feb 06.duc <br />