SITE INFORMATION AND CORRESPONDENCE

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Sutton and Teed-Bose -2 - 14 June 2004 3. The revised workplan does not address staff's 19 April 2004 Incomplete Report comments on the adequacy of the groundwater monitoring network. The previous comment was, "Staff notes that the groundwater monitoring network for the existing ponds is inadequate. The workplan shall be revised to add a sufficient number of groundwater monitoring wells to adequately characterize the groundwater quality for all ponds, including the existing ponds." Please provide proposed improvements to the groundwater monitoring network to adequately monitor the wastewater discharge. Please contact staff to finalize the well locations prior to submitting a revised report. 4. Section 4.3 describes the drilling technique to be hollow stem auger but Figure 6 indicates centralizers will be used in the installation. Centralizers are not required when wells are constructed in hollow stem augers. Please clarify Figure 6. 5. The revised workplan does not include well construction details for both shallow and deep wells as requested in staff's 19 April 2004 Incomplete Report correspondence. The statement, "The annular space from the top of the bentonite to the existing grade, if feasible, will be filled with neat cement containing three to five percent bentonite by weight,"is troublesome. Staff previously commented in the 19 April 2004 Incomplete Report correspondence, "because the area is characterized by hot and dry summers, staff is concerned that bentonite may dry and crack in the summer months. Please maximize the use of neat cement/bentonite in the annular seal..." Please describe how the annular seal will be maximized to prevent applied wastewater from impacting water quality in poorly constructed wells. 6. Please clarify the text in Section 5.1. It is unclear why Sample 11A and 12A are located 1,000 to 2,000 feet upstream of the Reclamation Field. In addition, it is questionable if Sample 11A is upgradient of the wastewater application considering the location of Proposed Reservoir 2A and 2B. Please redesign the ditch monitoring sample locations and address the 19 April 2004 Incomplete Report comment that stated, "Please add a monitoring location for each of the drains. Because much of the drain may be dry, selection of a sampling point for each drain can be established based on a description such as, `The furthest upstream a sample can be collected in Drain No._, but no further upstream than—' This approach will require identifying each drain and the area from which a sample can be collected." Please contact staff to finalize the drain sample locations prior to submitting a revised report. Please submit the revised workplan in accordance with your schedule. However, please note that the WDRs require one year of monthly sampling prior to using new land application areas, and therefore the revised workplan must be submitted at least 15 months prior to your plan to use the new ponds and/or land application areas. By 14 July 2004, Mountain House CSD shall submit a schedule that presents the wastewater system improvements. The schedule shall present the workplan submittal, well installation, new pond construction,monitoring tasks, and assumptions on when the land areas will be ready for wastewater application. Failure to adequately characterize the groundwater quality at the proposed ponds and/or land application areas may result in delays in Regional Board approval to use the improvements. Mountain House CSD and Trimark Communities shall submit quarterly monitoring reports that tabulate all groundwater data collected to date during the characterization phase. The monitoring reports shall include all the groundwater data collected, including data collected at the wastewater storage ponds and W:lSull`ObnmTS Iwi9uinVAnunuw lkewlSuYOnB c1U,une W.tl