SITE INFORMATION AND CORRESPONDENCE 1980-1999

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determining the cumulative loading of these pollutants. The Discharger must keep records of the is volume of irrigation water applied by acre to each section to enable the Board to determine the kilograms per hectare of metals and other priority pollutants that have applied through irrigation. This information should be submitted to the Board at the end of each irrigation season. D. Soil Profile Monitoring. Fields irrigated by wastewater border the public access ponds to the Northwest. This area periodically floods. We are concerned that pollutants may contaminate groundwater,leach from the soil during flood events and be transported to public lands and receiving waters. Since industrial and domestic wastewater are applied to land, how is the Regional Board going to determine the extent and content of priority pollutants that have been spread over the years unless testing is conducted. Soil profile sampling must include priority pollutants. E. Groundwater Monitoring. The Regional Board has identified the beneficial uses of the groundwater in this area as industrial, agricultural and municipal. In order to protect the beneficial uses of the underlying groundwater from contamination,the Discharger needs to test for all priority pollutants. Item G-3 specifies that"[t]he discharge shall not cause the groundwater to exceed water quality objectives, unreasonably affect beneficial uses, or cause a condition of pollution or nuisance." It is impossible for the Regional Board to determine compliance with this requirement unless groundwater monitoring includes priority pollutants. DeltaKeeper objects to the inclusion of"unreasonably affect beneficial uses"in Groundwater Limitations, G-3,because it could be interpreted as allowing the contamination of groundwater to the equivalent of domestic wastewater. We also object to the language in Groundwater Limitation, G-2,that states that increases in waste constituent concentrations, when compared to background, shall not exceed the increase typically caused by the percolation of domestic wastewater. We suspect that this language was included to prevent salt buildup. However, it should be clarified as it could be interpreted as applying to other pollutants. It is unreasonable to expect people to drink sewage. We recommend the Regional Board delete item G-2 and modify Item G-3 to read"[t]he discharge shall not cause the groundwater to exceed water quality objectives, affect beneficial uses, or cause a condition of pollution or nuisance (i.e., groundwater shall not be degraded compared with upgradient). F. Storage Pond Monitoring. DeltaKeeper members and staff have frequently noticed a stench coming from the facility as they travel on Interstate 5 or visit the wildlife area northwest of the plant. It is obvious that the DeltaKeeper,Tentative NPDES Permit,Lodi, 17 December 1999,Page 11.