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California Regional Water Quality Control Board Central Valley Region !'NViir{iWENM. HEAI.111 ' Robert Schneider,Chair P r'PY1T rERVICF surf Winston H.Hickox Gray Davis Secretaryfor Sacramento Main Office 03 JUL 29 PM 12' 55 Governor Environmental Internet Address: http://www.swrcb.ca.gov/mgcb5 Protection 3443 Routier Road,Suite A,Sacramento,California 95827-3003 Phone(916)255-3000•FAX(916)255-3015 28 July 2003 Vincent Westphal Bear Creek Winery 11900 N. Furry Road Lodi, CA 95240 RESPONSE TO ADDITIONAL MONITORING WELL INQUIRY, BEAR CREEK WINERY, SAN JOAQUIN COUNTY I have reviewed the 27 June 2003 Additional Monitoring Well(s) letter prepared by Fall Creek Engineering (FCE)that requests a"...written explanation identifying the evidence that supports requiring them to provide new monitoring wells at this time," and a delay in the installation of new groundwater monitoring wells. The Regional Board's request for a workplan to install additional groundwater monitoring wells was included in a 28 April 2003 California Water Code Section 13267 Order for Technical Reports and was originally included in 10 December 2002 Tentative Waste Discharge Requirements (WDRs). The request for a delay is denied; the installation of additional groundwater monitoring wells is necessary to evaluate the impact that the wastewater application may have on groundwater quality. As described below, the existing groundwater monitoring network is inadequate. Installation of groundwater monitoring wells is commonly required to establish background groundwater conditions prior to wastewater application and Bear Creek Winery (BCW) is presently applying wastewater to a number of land application areas that are not equipped with groundwater monitoring wells. It should be understood that groundwater monitoring wells may not be required at all land application areas immediately,but wells are required for all active land areas and will be required prior to application of wastewater as each new land area is brought into service. It is reasonable and cost effective from BCW's perspective to prepare a groundwater monitoring well installation workplan that describes where all the wells will be located thereby presenting a unified monitoring plan in one report. The alternative is to submit a series of workplans to address new land application areas as they are needed for wastewater application. Staff note that the request to delay installation of groundwater monitoring wells is a fundamental change in position for FCE, having recommended installation of an additional well in numerous documents, even as recently as the 31 January 2003 Review of Tentative Waste Discharge Requirements letter. In addition, FCE's 27 June 2003 letter does not accurately present the history of the groundwater investigation at the site, stating, "While the need to make our case on the basis California Environmental Protection Agency cycled Paper The energy challenge facing California is real. Every Californian needs to take immediate action to reduce energy consumption. For a list of simple ways you can reduce demand and cut your energy costs,see our Web-site at http://www.swrob.ca.gov/mgcb5