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CITY COUNCIL THOMAS A. PETERSON <br /> rCITY OF LODI <br /> City Manager <br /> JOHN R. (Randy)SNIDER, Mayor <br /> ALICE M. REIMCHE <br /> DAVID M. HINCHMAN City Clerk <br /> Mayor Pro Tempore CITY HALL, 221 WEST PINE STREET <br /> EVELYN M. OLSON CALL BOX 3006 BOB McNATT <br /> JAMES W. PINKERTON, Jr. LODI, CALIFORNIA 95241-1910 City Attorney <br /> FRED M. REID (209) 334-5634 <br /> TELECOPIER:(209)333-6795 <br /> October 19, 1989 FIECEIVE D <br /> Atm? 0 1989 <br /> ENIVIRONMENTAL HE�ALTH <br /> Environmental Protection Agency PER MIT/SERVICES <br /> Attention: Ed Wyatt (W-6-2) <br /> 215 Fremont Street <br /> San Francisco, CA 94105 <br /> SUBJECT: Victor Fine Foods Injection Well (EPA UIC Permit #CAS89000000i) <br /> The City of Lodi Public Works Department has reviewed the Fact Sheet and <br /> Draft Injection Well Permit for Victor Fine Foods. As the operators of the <br /> largest groundwater-supplied public water supply system within the <br /> three-mile radius of influence, we are very concerned about the potential <br /> impact on the groundwater basin. <br /> We note that we were not sent a copy of the fact sheet and draft permit <br /> until we made a verbal request and that the copy we received is <br /> incomplete. The workshop and public hearing dates were left out. We have <br /> learned from the Regional Water Quality Control Board that they are <br /> scheduled for October 25 and 26 in Lodi . We plan to attend. We would also <br /> like the opportunity to review the matter with you prior to the workshop. <br /> We can make space available at City Hall for this if you wish. <br /> Our specific concerns relate to protection of the underground water supply <br /> which provides high quality drinking water to the City of Lodi and rural <br /> areas. Some of our specific concerns are: <br /> ° Existing or Abandoned Deep Wells - We would like to review your records <br /> of these wells; we may have local knowledge of wells not contained in <br /> State records. Assuming there are none other than what is in your <br /> records seems risky. <br /> ° Adequacy of Confining Layers - While our experience is primarily with <br /> shallower drinking water wells, we consistently do not find evidence of <br /> uniform layers. We do not see how the fact sheet, Page 4, can state, <br /> the majority of voids are not interconnected". <br /> ° Confining Layer Monitoring - While it appears the injection well itself <br /> is adequately monitored, we see no requirement for monitoring the stratum <br /> above the confining layer. If there is a long-term leak, will we be <br /> able to tell only after TDS levels rise in our deeper wells? <br /> LEPA/TXTW.02M <br />