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Doug O'Neal • • <br /> April 24, 2002 <br /> Page 2 <br /> COMMENTS AND RECOMMENDATIONS <br /> • Collectively, the above-referenced monitoring reports for the 2001 reporting year meet the <br /> minimum reporting requirements of California Code of Regulations, title 22, section <br /> 66264.97(e)(14)(15)(16). <br /> ■ The facility has adequately addressed GSU comments on the 2000 Annual Report (DTSC <br /> 2001 a). <br /> • As part of our review, GSU evaluated whether the facility sampled all wells identified under <br /> the Department of Toxic Substances Control (DTSC) Post-Closure Permit and the Central <br /> Valley Regional Water Quality Control Board (RWQCB) Monitoring and Reporting Program <br /> No. 91-220 (MRP 91-220). GSU's evaluation considered the 1997 modification to the DTSC <br /> Post-Closure Permit. Based on this review, the following wells were not sampled during <br /> 2001: <br /> Well No. Requirement FrequencyParameters Comment <br /> B-1 DTSC Annual VOC no comment <br /> B-4 DTSC Annual VOC no comment <br /> B-5 DTSC Annual VOC no comment <br /> KS-7 DTSC, RWQCB Annual VOC, H, EC,TDS Paved over since 1996 <br /> SMW-1 DTSC Annual VOC no comment <br /> SMW-2 DTSC Annual VOC no comment <br /> SMW-3 DTSC Annual VOC Well dry throughout 2001 <br /> SMW-4 DTSC Annual VOC no comment <br /> SMW-5 DTSC Annual VOC no comment <br /> SMW-6 DTSC Annual VOC no comment <br /> KI-7 DTSC, RWQCB Annual VOC, pH, EC,TDS I Paved over since 1996 <br /> Wells KS-7 and KI-7 are no longer included in the list of monitoring wells to be sampled <br /> under RWQCB Monitoring and Reporting Program No. 5-01-269 (MRP 5-01-269) adopted <br /> on December 7, 2001. San Joaquin County requires decommissioning of wells that are not <br /> in use for one year. GSU recommends that the facility submit a workplan to locate and <br /> decommission wells KI-7 and KS-7. <br /> Based on the discussion provided on Page 12 of the 2001 Annual Report, the facility <br /> identifies wells B-1, B-4, and B-5 as wells to be sampled under the DTSC Post-Closure <br /> Permit. Although no explanation is provided, GSU assumes that wells B-1, B-4, and B-5 <br /> were not sampled because of slow recharge. If the wells have slow recharge, the well <br /> should be purged to dryness, allowed to recover, and a sample taken when sufficient water <br /> is present. GSU comments on the draft water quality sampling and analysis plan (WQSAP) <br /> also discussed this issue (DTSC 2002). Alternatively, if the saturated thickness of the <br /> screened interval is less than ten feet long, the facility could use low-flow purging and <br /> sampling methodology. If the facility pursues this alternative, procedures for low-flow <br /> purging and sampling should be included in the next version of the WQSAP submitted to <br /> DTSC and RWQCB for approval. <br /> Based on the discussion provided on Page 12 of the 2001 Annual Report, the facility does <br /> not identify wells SMW-1 through SMW-6 as being required to be sampled under the DTSC <br /> Post-Closure Permit. Despite the file review, it is not clear to GSU whether these wells were <br /> addressed by the 1997 DTSC permit modification. GSU recommends that DTSC verify <br /> whether these wells are required to be sampled under the DTSC permit. Regardless of this <br />