Laserfiche WebLink
CalifornoRegional Water Quality Cderol Board ' <br /> Central Valley Region G­l <br /> Robert Schneider C _ <br /> hair <br /> Dan Skopee Arnold <br /> AcvrngSecretary Sacramento Mann Office Schwarzenegger <br /> 11020 Sun Ccnler Drive#200,Huncho Cordovu,Culifornia 956746114 <br /> Phonc(916)464-3291 -FAX(9 16)464-4645 Governor <br /> httt)://www,watcrtx)urds.cn.gov/cenlralvalley <br /> 20 April 2006 <br /> Pae3-It"Fax Note 7671 °a1e ¢ L,r o� pdQe9� <br /> TO <br /> Paul Franzia Go./Dept. co. <br /> Barrel Ten Quarter Circle Land Company Pt,one r Phone to <br /> 6342 Bystrum Road Fax« y Fax« <br /> Ceres, CA 95307 <br /> CONDITIONAL APPROVAL, BARREL TEN WINERY, ESCALON, SAN JOAQUIN COUNTY <br /> I have reviewed the 31 March 2006 Groundwater Investigation Work Plan, prepared by <br /> Kennedy/Jenks Consultants. The Workplan was prepared to describe additional investigation <br /> of groundwater quality and potential sources of groundwater constituents of concern near the <br /> Barrel Ten winery. Staff considers the groundwater quality at the winery to be degraded as a <br /> result of site activities, including land application'of wastewater; the Discharger has stated off- <br /> site sources may be responsible for some of the groundwater conditions observed. The <br /> Workplan describes activities that will provide data to better characterize the source of <br /> groundwater degradation. <br /> I have the following comments on the Workplan: <br /> 1. In Section 1.8, the Workplan states, "The locations of these two wells [MW-6 and MW-7] <br /> are considered cross-gradient relative to groundwater flow (Figures 3 and 4)." Staff does <br /> not agree with that assessment. As previously stated in the 14 October 2003 Conditional <br /> 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 <br /> quality and wastewater percolate. <br /> 2. Section 1.8.1 states, "Surface water was estimated in the Effluent Limit Determination <br /> Technical Report to take approximately 50 years to reach groundwater at 55 feet bgs, <br /> according to the soil moisture loading model." Staff recognizes the slow nature of <br /> groundwater flow, but if the data from the pan lysimeters provided in the 12 August 2004, <br /> Effluent Limit Determination Technical Report, is considered, groundwater conditions may <br /> worsen considerably as a result of the continued discharge. The pan lysimeters <br /> contained percolate with Fixed Dissolved Solids (FDS) concentrations often greater than <br /> 3,000 mg/L. If the percolate reaches groundwater, it will result in further groundwater <br /> quality degradation. <br /> 3. Section 1.8.2.3 describes locating off-site sources, but the proposed drilling and sampling <br /> locations have already been determined. It may be prudent to identify potential sources <br /> first, and then perform sampling to determine if they have impacted groundwater quality. <br /> The chemical constituent concentration contour figures are flawed because they contain <br /> errors such as inconsistent contour interval_, missed contour lines, and the interpretation <br /> ignores groundwater flow direction considerations related to hydrodynamic dispersion. <br /> The additional data provided in this investigation may clarify the interpretation. <br /> California Environmental Protection Agency <br /> Ca Hecycled Parer <br />