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California Regional Water Quality Control Board e Central Valley Region Winston 11. Hicltos Steven T. Butler, Chair Gray Davis Secretary for Governor nvtronmenfO! Sacramento Main Office Protection Internet Address: http://www.swrcb.ca.gov/—rwgcb5 3443 Routier Road,Suite A,Sacramento,California 95827-3003 Phone(916)255-3000-FAX(916)255-3015 p 21 November 2000 MGMZVM 0 N O V 2 2000 Mr. Richard Prima B Y:`-- -_ ------ Director of Public Works City of Lodi Post Office Box 3006 Lodi, CA 95241 REVIEW OF GROUNDWATER EVALUATIONREPORTAND REQUEST FOR WORKPLAN, ORDER 3-00-031, WHITE SLOUGH WATER POLLUTION CONTROL PLANT, LODI, SAN JOAQULY COUNTY The Regional Board has received the Groundwater Evaluation Report for the City of Lodi White Slough Water Pollution Control Plant dated.October 2000 and received 30 October 2000. The report was prepared by Saracino-Kirby, Inc. on behalf of the City of Lodi pursuant to Provision H.11. of NPDES permit, Order No. 5-00-031. Provision H.11. required that"Within 270 days of adoption of the permit, the Discharger.shall submit a report regarding the adequacy of the existing wells for this purpose, and the need for additional well(s). Plans and specifications for any additional wells) shall be submitted to Board staff for review and approval prior to construction, and shall be installed within 90 days of approval." I have reviewed the report and present my comments and request as follows: 1. The report identified many uncertainties that exist within the current groundwater monitoring program. I concur that there is insufficient information at this point in time to adequately evaluate if the practice of wastewater reclamation is altering groundwater background nitrate levels. 2. The report recommended that seven (7) additional groundwater monitoring well be constructed to supplement the existing groundwater monitoring wells. However, Figure 23 of the report identifies the proposed locations of eight (8) groundwater monitoring wells. 3. The City shall prepare and submit a groundwater monitoring workplan. The workplan shall be submitted to the Regional Board by 13 January 2001. This workplan shall clarify the actual locations and numbers of Groundwater monitoring wells to be installed. The workplan shall describe the plans and time schedule to construct the wells and to conduct the other recommendations cited in the report. The workplan shall follow the guidance of California YVell Standards, California Department of Water Resources Bulletins 74-81 and 74-90. California En virolimental Protection.4o eney JRecycled Paper