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\._1 U southeast comer of the wastewater treatment plant),but the monitoring well data from the Spreckels/Holly Sugar facility as well. Solely using well HP-5 as an indicator of the local background,as the CVRWQCB does in Attachment F of Order No.R5-2007-0038, misrepresents both local and regional groundwater quality conditions. The Spreckels/Holly Sugar site has multiple wells that provide'background' groundwater quality data over a period of years. These wells provide additional data to support variability,but do not have sufficient data to provide full statistical comparison at this time. The City proposes to continue monitoring these wells on a semiannual basis to eventually enable having a sufficient'background groundwater quality' data base. Table 1 summaries the available TDS,specific conductance,and chloride data for BW-2 and BW-6 (located east of B-4 in Figures 10 and 11). The Spreckels/Holly Sugar site owners argued in its January 15,2006 report (Minney 2006) that TDS"site-specific shallow background groundwater was determined to be 3,665 mg/L" and that the"standard for usable or treatable groundwater for drinking water purposes set by Resolution 88-131 is 3000 mg/L)". The report indicates that the beneficial uses of the site groundwater should be considered unaffected by factory discharges." The City requests that the CVRWQCB provide information to the City as to whether that assertion was accepted by the CVRWCB. If the CVRWQCB considers existing groundwater conditions at the Spreckels/Holly Sugar site to meet the criteria defined by Resolution 88-13,then similar consideration should be accorded to the W WTP site. Further discussion of the Resolution 88-13 is required. The City proposed to sample the existing wells BW-2 and BW-6 to increase the size of the background data set until a decision is reached. Background Well The CVRWQCB indicates that the proposed background well location for the holding ponds/drying beds may be considered too close to the existing sludge drying beds. This location was proposed because it was at the extreme southwest comer of the City-owned property at the W WTP facility,which is bounded by Holly Drive and West Larch Road. It will be located as far from the drying beds as possible,as long as the well can be protected by the existing signs and/or trees. The well is planned to be located approximately 80 feet away from the beds themselves, pending utility clearance. Although this is not an ideal situation,there do not appear to be reasonable alternate locations. The regional direction of groundwater flow is to the north. 1 The report cites 88-13,but the correct reference to this policy(Souources of Drinking Water)is 88-63.