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STATE OF CALIFORNIA PETE WILSON, Governor CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD— 1 ' CENTRAL VALLEY REGION 3443 ROUTIER ROAD, SUITE A SACRAMENTO, CA 95827-3098 *o PHONE: (916) 361-5600 FAX: (916) 361-5686 Aft JIM now 24 July 1991 "� ' .� V - J U L 3 0 9991 ENVIRONMENTAI. HFALTH Mr. Bill Duckenfield PERM IT/; � Victor Fine Foods P. 0. Box 147 Lodi , CA 95240 PROPOSED MONITORING PROGRAM REVISIONS, VICTOR FINE FOODS, SAN JOAQUIN COUNTY We have reviewed your request for changes in Revised Monitoring and Reporting Program (RM&RP) No. 90-047 dated 2 May 19091. oased an the informatio^ submitted, many of your changes can be accomodated. Some of the changes requested were not substantiated with any technical information. Enclosed is a draft "Second Revised Monitoring and Reporting Program No. 90-047. We will wait for your comments on the draft and this letter prior to asking the Regional Board's Executive Officer to sign the new monitoring program. We had held up revision of the RM&RP because we were under the impression that an additional report would be sent to us by Harding Lawson and Associates. The following are our comments on the RM&RP revisions proposed by Nolte and Associates. PRODUCTION WASTEWATER MONITORING While the data you submitted for January through April 1991 indicates a fairly consistent Electrical Conductivity (EC) to Total Dissolved Solids (TDS) ratio of 2: 1 , our review of data back to June 1989 indicates a ratio of 1 .5: 1 or less for data submitted prior to July 1990. Also, the EC/TDS ratios for production wastewater, plant effluent, and extracted ground water were all different for each type of wastewater. The Nolte proposal did not contain any explanations for the significant change in the production wastewater EC/TDS ratio or the differences between the ratios. Furthermore, using four months Of data to justifv changes in a monitoring program is not sufficient when additional data is available. The correlation between EC and TDS is necessary in order to validate the use of EC to determine if ongoing corrective actions are resulting in a reduction in salts in the vadose zone and ground water beneath the site. Also, if leaks in EESB or changes in geochemistry occur in the future, the correlation will help evaluate the impacts of your wastewater disposal operations on the soil and ground water beneath your site. Therefore, we request that Victor develop a range of background EC and corresponding TDS values that are representative of existing soil and ground water conditions beneath the site. Since Victor will continue to monitor EC and TDS on some samples, Victor will be able to confirm the EC/TDS relationship in the future. Therefore, we substituted EC for TDS in the proposed monitoring program.