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' Cary Keaten 0 - 4 - 0 10 April 2007 b. The introduction to the bullet list refers to two publications related to groundwater sampling. The samples must be collected consistent with the EPA laboratory ' method. c. Table 2 does not include the analyte hardness; please add it to the table. Also add a "Sample Hold Time" column to Table 2. d. Please add "Purge Water Discharge To Land Application Area No. line at the bottom of the Well Development Log and the Well Purging and ' Sampling Log. As described above, discharge of purge water to the land surrounding the monitoring well may be acceptable but it should never be discharged to a stormwater drain or surface water feature. ' e. Bullet No. 6 states, "...purge water shall be spread on land or the disposal area," and also refers to a "disposal field." Please use terms that are consistent with the ' WDRs. The proper name for areas where wastewater is applied is a "land application area." Appendix B Review Appendix B of the workplan includes three reports on the status of groundwater monitoring wells; it is unclear why they were submitted in the Master Workplan and which registered professional is responsible for the work described by the reports. Those reports shall be resubmitted as stand alone documents, each clearly indicating the California licensed professional that supervised the work and preparation of the report. 1. In the 13 January 2006 Monitoring Well Location Study, prepared by Engeo Inc., please address the following: ' a. The report describes several wells that cannot be located and recommends no further action. However, there is no description of the well construction or evaluation whether the lost wells may act as a vertical conduit for ground or surface water to migrate to lower aquifers. The wells listed as lost include the following: MW-12, MW-14, MW-16, MW-17, MW-19, MW-21, and MW-22. Staffs ' review of the project file did not locate any information on the construction of the lost wells. Please describe what information you relied upon to determine the well construction and the potential for the well to act as a vertical conduit. ' b. All of the lost wells are listed in Finding No. 62 of the WDRs as part of the groundwater monitoring network. Well MW-12 is designated as a well from which samples will be chemically analyzed. The wells must be replaced. By 29 June 2007, please submit a Groundwater Well Project Description Addendum describing a groundwater monitoring well installation for Wells MW-12, MW-14, ' MW-16, MW-17, MW-19, MW-21, and MW-22. Also include replacement of Well MWA 8 in the Addendum (reported as destroyed in the 13 February 2007 Monitoring Well Destruction Report). c. The statements in the report, "...therefore we are not proposing any further action for these wells," and "If, at anytime, the above-mentioned wells are no longer needed, they will be abandoned in accordance with San Joaquin County's ' requirements," are contrary to the WDRs. W\WTkOHn MS JmpinLL&W,WWT R 6 MGDVCutm 8 Ma 07.d