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California Regional Water Quality Control Board Central Valley Region Robert Schneider,Chair Winston H.Hickox Gray Davis Secretaryfor Sacramento Main Office Governor Environmental Internet Address: http://w .swrcb.ca.gov/—mgcb5 Protection 3443 Routier Road,Suite A,Sacramento,California 95827-3003 Phone(916)255-3000•FAX(916)255-3015 13 June 2001 JUN 14 2001 Mr. Andy Alexander Ef' I' ��' 17 California Concentrate Company ' ``"''' 18678 North Highway 99 Acampo, CA 95220 CONDITIONAL APPROVAL, GROUNDWATER MONITORING WORKPLAN, CALIFORNIA CONCENTRATE COMPANY, ACAMPO, SAN JOA Q UIN CO UNT Y I have reviewed the 8 June 2001 Revised Groundwater Monitoring Workplan for California Concentrates, prepared by Jacobson Helgoth Consultants. The plan was prepared in response to a 14 February 2001 Regional Board request for reports pursuant to Section 13267 of the California Water Code and a 29 May 2001 review of the 18 May 2001 Groundwater Monitoring Workplan. Many of the comments provided in the 29 May 2001 workplan review were not addressed in the revised workplan and therefore are repeated below. After reviewing the latest workplan, I have the following comments: • The workplan states that Well MW-2 will be used for groundwater elevation data collection only. Because the groundwater flow direction is not established, it is inappropriate to not include the well in the current monitoring program. All the wells shall be included in the groundwater monitoring program. After collecting four quarters of data, you may request that staff consider revising the groundwater monitoring network. • Consider relocation of Well MW-5 to the west of the location presented in the workplan. If the well locations do not monitor the groundwater flow direction upgradient and downgradient of the wastewater ponds and land application areas, additional wells may be required. • Permits from the San Joaquin County Environmental Health Department(SJCEHD) are required for installation of groundwater monitoring wells. • SJCEHD Well Standards Section 13.10.8 recommend surging the sand pack prior to installation of the transition seal. Section 13.15 lists recommended well development techniques. The amount of water proposed to be pumped from the wells (0.48 gallons/saturated foot)may not be adequate to develop the wells, especially if other development techniques are not employed. • Please provide a table that presents the analytes, analytical method, container size, container material, preservatives, and analytical method hold times. Groundwater measurements and analytes that are required in the revised monitoring program are listed below: - Elevation, - Nitrate as Nitrogen, - Total Dissolved Solids, California Environmental Protection Agency ea 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 http://w .swrcb.ca.gov/rwgcb5