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BILL DUCKENFIELD 2 24 July 1991 PRETREATMENT PLANT EFFLUENT MONITORING You have requested a change in the Pretreatment Plant Effluent Monitoring from BODS to COD and made reference to published material written by Metcalf & Eddy. Although no supporting documentation was included with the Nolte proposal , we will revise this part of the monitoring program since you are no longer discharging to the Mokelumne River. If in the future Victor discharges to Mokelumne River, then it is likely that Regional Board NPDES staff will require Victor to resume BODS sampling of the effluent. EXTRACTED GROUND WATER MONITORING We will reduce the general minerals to an annual sampling event and the specific minerals identified in your letter will be sampled quarterly. EQUALIZATION/EMERGENCY STORAGE BASIN MONITORING Except for reporting the freeboard in the EESB and two vadose zone sampling events, Victor has not submitted any further information required by RM&RP No. 90-047. Annual LCRS Testing and weekly synthetic liner inspections are required and no monitoring reports submitted to date include any results or demonstrate that any of the monitoring is being conducted. These noncompliance issues were identified in a 1 May 1991 Notice of Violation letter. LCRS Leachate Monitoring Victor has not submitted any information to suggest that any leachate generation has occurred. We can assume either that no leachate generation has occurred or that Victor has not been sampling according to RM&RP No. 90-047. If there is no leachate in the LCRS, then there is no need to sample or reduce the sampling frequency in a detection monitoring program that is not currently being utilized. Consequently, there will be no change in the constituents or the sampling frequency until leachate generation occurs and enough samples have been collected to justify a modification in the monitoring program. Vadose Zone Monitoring In your 2 May 1991 letter, you state, "In the past year, quarterly vadose zone monitoring has now established the baseline water quality. . . ". First, only two of the required four quarterly vadose zone sampling event results have been submitted as required by RM&RP No. 90-047 to determine the Water Quality Protection Standards (WQPS) . Second, since the WQPS have not been established for the vadose zone at this site, then it is not possible to conclude whether or not there has been a statistically significant increase over WQPS. As stated in our 1 May 1991 letter, Victor must determine if there is a statistically significant increase over WQPS and demonstrate correlations or trends that supports a reduction in sampling constituents before we will consider revising the monitoring program. It should be noted that Article 5 of Chapter 15, Title 23, California Code Of Regulations which became effective 1 July 1991 provides specific direction for developing WQPS and determining if there has been statistically significant increase over WQPS.