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Kennedy/Jenks Consultants <br /> Engineers&Scientists <br /> 622 Folsom Street <br /> San Francisco, California 94107 <br /> 415-243-2150 <br /> 25 August 2006 FAX 415-896-0999 <br /> V <br /> VLI U <br /> Mr. Tim O'Brien AUG 2 u 11006 <br /> California Regional Water Quality Control Board ENVIRC <br /> Central Valley Region PERONMENT f�EALrH <br /> 11020 Sun Center Drive #200 /SERVICES <br /> Rancho Cordova, CA 95670-6114 <br /> Subject: Groundwater Investigation Work Plan — Response to Conditional Approval <br /> Barrel Ten Quarter Circle Land Company, Inc., Escalon Winery, Escalon, California <br /> K/J 030118.08 <br /> Dear Mr. O'Brien: <br /> Kennedy/Jenks Consultants (Kennedy/Jenks) has prepared this letter on behalf of Barrel Ten <br /> Quarter Circle Land Company (BTQCLC) in response to the Conditional Approval, Barrel Ten <br /> Winery, Escalon, San Joaquin County (Conditional Approval) issued by the California Regional <br /> Water Quality Control Board, Central Valley Region (CRWQCB) on 20 April 2006. This letter <br /> provides clarification to comments in the Conditional Approval related to the Groundwater <br /> Characterization Work Plan (Work Plan) submitted to the CRWQCB by BTQCLC on <br /> 31 March 2006. <br /> Response to Comments on the Work Plan <br /> CRWQCB comment 1: In Section 1.8, the Work plan states, "The locations of these two wells <br /> (MW--6 and MW-71 are considered cross-gradient relative to groundwater flow(Figures 3 and <br /> 4)."Staff does not agree with that assessment. As previously stated in the 14 October 2003 <br /> Conditional Approval, the close proximity of the wells to the land application areas may result in <br /> samples collected from that area representing a mixture of background groundwater quality and <br /> wastewater percolate. <br /> Response: The general groundwater flow direction beneath the winery and associated land <br /> application areas (collectively referred to as the Site) has consistently been north by northwest <br /> as characterized by data from existing onsite monitoring wells (see Figure 4 of the Work Plan). <br /> The configuration of the land application areas (LAA) creates a long and narrow Site in a north- <br /> south axis, and groundwater generally flows at a slight angle across the length of the LAA. The <br /> corresponding groundwater flow direction and LAA configuration makes it difficult to assign a <br /> designation of upgradient or downgradient that is appropriate for a well relative to all of the LAA. <br /> Well MW-6 is upgradient of basins 1, 2, and 4 but could be considered cross-gradient of basins <br /> 3 and 6, and perhaps downgradient of basin 7. Well MW-7 could only be considered upgradient <br /> of basin 2 and perhaps basin 1 but cross-gradient with basins 3, 4, 5, 6, and 7. The cone <br /> penetrometer test (CPT) work discussed in the response to CRWQCB comment 3 below is <br /> intended to address the issue of commingled groundwater at and near the Site. <br /> g:Vs-groupWminljobl031030118.08_barreltenl06-corrspndllbsVspns cmmtslcmmts-01.doc <br />