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0 0 <br /> Vincent Westphal -2 - 22 August 2003 <br /> • The number of proposed wells does not allow evaluation of all the active land application areas <br /> described in the March 2002 RWD. The groundwater monitoring network must provide information <br /> on upgradient groundwater quality and monitor downgradient of all active land application areas. <br /> Please revise the number and location of the proposed wells. <br /> • Figure 1 in the workplan is not consistent with Figure 1.2 presented in the March 2002 RWD. Staff <br /> notes that FCE commented on an incorrect representation of the area in Attachment B 1 in the <br /> 10 December 2002 tentative WDRs. The incorrect figure is significant because it implies Well <br /> MW3 is located downgradient of a portion of the 12-acre land application area. Staff's review of the <br /> data presented in the groundwater monitoring events indicates no well is clearly downgradient of the <br /> 12-acre land application area. Please review the figure, correct it as necessary, and consider the <br /> revision in proposing the location of additional wells. <br /> • Volatile organic compounds is not listed on Table 1, but is required by the Revised Monitoring and <br /> Reporting Program (Revised MRP). Please add volatile organic compounds to the list of analytes. <br /> Prior to your scheduled drilling date of 29 August 2003 please resubmit the workplan and address the <br /> comments listed above. Failure to provide a workplan that responds to the scope of groundwater <br /> monitoring required in previous documents will lead to staff recommending an enforcement action. If <br /> you have any questions on this workplan review,please telephone me at (916) 255-3116. <br /> TIMOTHY R. O'BRIEN <br /> Waste Discharge to Land Unit <br /> San Joaquin River Watershed <br /> cc: Mike Huggins, San Joaquin County Environmental Health Department, Stockton <br /> Peter Hasse, Fall Creek Engineering, Santa Cruz <br /> f <br />