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Richard Prima -2 - 20 August 2003 <br /> City of Lodi Public Works Department <br /> San Joaquin County <br /> been completely evaluated and the no impact conclusion is offered without considering half the <br /> data. <br /> Report Recommendations and Regional Board staff comments: <br /> 1. Digital data recorders are recording groundwater elevations every 60 minutes. <br /> Comment: While it may be highly technical to view hourly or diurnal fluctuations of <br /> groundwater elevations, this much data seems to be over powering and with out much report <br /> evaluation and justification. The quarterly gradient and direction are not calculated as required <br /> by the Monitoring and Reporting Program No. 5-00-031. <br /> 2. The City should implement changes to its effluent management practices to avoid nitrogen <br /> overloading. <br /> Comment: After concluding the facility has had no impact on groundwater, the report <br /> recommends a review and changes to operations. The recommendation to avoid nitrogen <br /> overloading should be standard practice. The report should consider Specific Conductivity, <br /> which is already monitored and should consider adding Total Coliform Organisms to the effluent <br /> monitoring also. <br /> 3. Additional well installations are recommended up and down gradient of the facility. <br /> Comment: The explanation to support additional well installations says that flow direction and <br /> water quality may not have been accurately determined with two years data from nineteen wells <br /> due to lack of background data. Prior to installing additional wells flow gradient and direction <br /> should be calculated and all of the data collected should be included or ruled out as not <br /> contributing pertinent information(i.e. add Specific Conductivity and Total Coliform <br /> Organisms). The addition of two other constituents may provide additional insight to the <br /> problem and enhance the analysis. <br /> 4. Water in the surrounding water bodies is to be monitored for migration underneath the facility. <br /> Comment: This may be a determining factor and deserves to be ruled out with additional data. <br /> 5. Monthly groundwater monitoring has been started to verify large fluctuations in the nitrate data. <br /> Comment: Minimal information has been presented showing the facility's nitrogen discharge <br /> loading and farming practices. The data that has been provided tends to support a theory of <br /> facility operations having an impact on groundwater. We do not clearly understand why an <br /> increase in data collection frequency is recommended when existing Specific Conductivity and <br /> Total Coliform Organisms data has not been fully evaluated. <br />