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Californi#egional Water Quality Cobol Board <br /> Central Valley Region <br /> Karl E. Longley,Seri,P.E.,Chair 0 <br /> Linda Adams Sacramento Main Office Arnold <br /> Secretnryfor 11020 Sun Center Drive#200,Rancho Cordova,California 95670-6114 Schwarzenegger <br /> Environmental Phone(9)6)464-3291 •FAX(916)4644645 /' Governor <br /> Prolection htip://www.waterboards.ca.gov/centralvalley flq <br /> 1 June 2007 <br /> Jury � \ � <br /> 1cN(v <br /> Robert Calvin Jim Crandell <br /> Constellation Wines U.S. R.M.E. Inc. /SFR�iS �h <br /> 12667 Road 24 P.O. Box 1260 FS <br /> Madera, CA 93637 Woodbridge, CA 95258 <br /> REVISED CEASE AND DESIST ORDER, R.M.E., INC., WOODBRIDGE WINERY, SAN <br /> JOAQUIN COUNTY <br /> Enclosed is the strike-through formatted revised Woodbridge Winery Cease and Desist Order <br /> that has been submitted for the Central Valley Regional Water Quality Control Board agenda. <br /> The Regional Water Board will consider approval of the revised Cease and Desist Order <br /> (CDO) at its meeting on 21/22 June 2007. Please note Regional Water Board legal staff is <br /> reviewing the document and additional changes are possible. <br /> Many changes were made to the tentative CDO based on the 14 May 2007 Kennedy/Jenks <br /> Consultants comment letter. However, the comment letter included a number of proposed <br /> changes that are not consistent with State policies regarding wastewater application. Those <br /> changes were not made and are discussed below: <br /> The letter proposes to abandon the use of background groundwater quality to determine if <br /> waste application has degraded groundwater quality. This approach is not consistent with <br /> the procedure that all other dischargers in the waste discharge to land program are <br /> required to follow and that is necessary to comply with State Water Resource Control <br /> Board Policy No. 68-16. Interwell comparisons are the standard for determining the impact <br /> of waste application. Intrawell comparisons (comparing the data from each well to itself <br /> over time) can be used if no waste has been previously applied, which is not the case at <br /> the Woodbridge Winery. The alternative approach presented by Kennedy/Jenks in the 31 <br /> July 2006 Report of Waste Discharge (RWD) cannot be used because the wells proposed <br /> for determination of "ambient' groundwater quality are already impacted by the waste <br /> application. <br /> Staff commented on a number of groundwater monitoring workplans stressing the <br /> importance of determining background groundwater quality, but the issues raised in those <br /> comments remain unresolved. Also, during our 12 April 2007 meeting, we discussed the <br /> issue of determining background groundwater concentration. In that meeting you agreed <br /> to consider use of a groundwater monitoring well located cross-gradient of the winery as a <br /> means to determine the natural mineralization rate of groundwater migrating through area <br /> sediments. That approach has apparently been abandoned without further consideration <br /> in favor of an approach that determines irrigation water used in the area. Staff note that <br /> the area well survey has already been performed and described in Section 3.1.2 of the 28 <br /> California Environmental Protection Agency <br /> � Recycled Paper <br />