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Vincent Westphal • -2 - • 28 July 2003 of data from monitoring well 1 is unfortunate, you should be reminded that you chose the location of monitoring iy0l 1. :BCW's preferred location for this monitoring well was at the end of Armstrong Road. It was placed where it is at your request." These issues are discussed in the History of Groundwater Investigations section of this letter. History of Groundwater Investieations On 1 September 2000, the Regional Board transmitted a Draft Revised Monitoring and Reporting Program that included a groundwater monitoring requirement. BCW was required to submit a groundwater monitoring well installation workplan by 30 November 2000. It was anticipated that BCW would begin groundwater monitoring by the Second Quarter of 2001. On 13 December 2000 Regional Board staff provided a Conditional Approval for the 27 November 2000 Monitoring Well Installation Workplan prepared by Applied Science and Engineering, Inc. (ASE). The Conditional Approval stated, among other items,the need for a fourth well downgradient of the secondary disposal area and an upgradient well located upgradient of the vineyard area. An 18 December 2000 Amended Monitoring Well Installation Workplan was prepared by ASE addressing most of the items in the Regional Board's 13 December 2000 Conditional Approval, however, the Regional Board, in a 2 January 2001 Second Conditional Approval stated the need for wells to be located downgradient of the secondary disposal area and requested a fourth well. The Regional Board received no response to the Second Conditional Approval. On 4 May 2001 while drilling the groundwater monitoring wells, Vince Westphal and Craig Rous of BCW, and Dick Armstrong of ASE informed staff in a conference telephone conversation that groundwater was deeper than anticipated and were concerned about well placement. In the telephone conversation, BCW and ASE asked if only three wells could be installed at that time and proposed to determine the groundwater flow before determining the need for additional wells. I agreed to limit the number of wells at that time to three, but informed BCW and ASE that the Regional Board's criterion is wells located upgradient and downgradient of application areas and that additional wells may be required in the future. The conclusion from the conference call was that BCW would evaluate the groundwater flow direction prior to drilling any additional wells. At this time, staff believes the groundwater flow direction has been investigated adequately to allow selection of the additional groundwater monitoring wells that meet the upgradient/downgradient criterion described in both Conditional Approval letters and the telephone conversation. Report of Waste Discharee History On 19 July 2001 the Regional Board issued a Request for Report of Waste Discharge (RWD) to update the facility's WDRs. RWDs are required to include a technical report that carefully evaluates the facility, wastewater system, and disposal techniques—including groundwater conditions. BCW submitted an RWD on 20 September 2001; the RWD was determined to be inadequate and a Water Code Section 13267 Order for a Report of Waste Discharge was transmitted on 19 November 2001. V:\Sen_laagwn Non15\Stafl\ObrienMan Joequin\Bear Creek\w tphal 21 July 03.d0c