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' Cary Keaten - 3 - 10 April 2007 5. In "Section D. Well Development," the section refers to "disposal fields," but the WDRs do not reference disposal fields. In general, it is preferable for waste to be applied to ' established land application areas. Depending on the amount of well development water generated, it may require the waste to be trucked to a land application area. However, if the well development/purge water infiltrates the local area, discharge at the ' well site may be acceptable. Discharge of development or purge water to a stormwater drain feature is not acceptable. Please address the waste disposal methods and avoid using terms that are not defined in the WDRs. ' 6. In "Section E. Well Survey," survey companies are listed by name. We suggest you include the phase, "Or similarly qualified land survey consultants that are licensed by ' the State of California." 7. In "Section F. Monitoring Well Destruction," please address the following items: ' a. The section fails to state that the work shall be performed under the supervision of a California licensed engineer or geologist. ' b. As required by WDRs Provision G.1.i.ii I., Groundwater Well Project Description Addendums are required prior to any groundwater monitoring well destruction workplan. c. The section only discusses one method of well destruction. We agree that over- drilling a well is the preferred method of well destruction, but there may be cases where other well destruction methods are appropriate or required by site ' constraints. Please update the discussion of well destruction with other potentially acceptable methods of well destruction. ' 8. In "Section G. Reporting," please include a reference to, and the Master Workplan should include a copy of, WDRs Attachment F, Requirements for Monitoring Well Installation Workplan and Monitoring Well Installation Reports. 9. In "Section I. Groundwater Sampling and Analysis Plan," please address the following items: a. As presented in the Master Workplan the discussion of the chemical analyses and the lack of discussion of the defined groundwater monitoring network is likely to result in confusion. Please address the following items: ' i. Established Monitoring Well Network - There is no distinction between groundwater monitoring wells that will be sampled for water level only and ' wells that will be sampled for water level/water quality. The monitoring well network for the currently allowed flow rate of 750,000 gallons per day is defined in Finding No. 62 of WDRs Order No. R5-2006-0094. Please add a ' discussion of the current monitoring requirements and how they may change with approval of future Recycled Water Expansion Reports. ii. List of Chemical Analyses - The Master Workplan includes substantially more ' analytes than required by the Monitoring and Reporting Program (MRP). Your may perform these additional analyses, but must submit the data with the required monitoring data. To clarify the minimum required monitoring, please add clarifying text to the section and a column to Table 2 that identifies analyses required by the MRP. ' WI UWA--nSui6 MGDV.n BMu 07.dog