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Page 3 of 4 <br /> rd <br /> Hi Frank, <br /> Thank you for your inquiry. Per our telephone conversation, in the <br /> City of Stockton's NPDES permit we required the City to comply with <br /> Groundwater Limitations (p. 16 of attached permit) , expressed as the <br /> greater of the groundwater water quality objectives or background water <br /> quality. Previously, the City applied a "present-day background <br /> concept" by using an intra-well comparison to determine background <br /> groundwater quality. However, Regional Water Board staff prefers the <br /> intra-well analysis used only when data is available prior to the <br /> Discharger discharging to groundwater. The City does not have site <br /> groundwater data prior to the Facility's existence, and thus, the City <br /> discharging to the groundwater. Therefore, the permit requires the City <br /> to install "additional monitoring wells and any other testing needed to <br /> effectively and fully characterize background quality conditions. " (pp. <br /> 25-26 Time Schedule for Compliance with Groundwater Limitations and Best <br /> Practicable Treatment and Control) <br /> If you need any additional information from me, please feel free to <br /> contact me. And again, thank you for contacting and inquiring about <br /> this matter. <br /> Respectfully, <br /> Gayleen <br /> Gayleen Perreira, P.E. <br /> Water Resource Control Engineer <br /> Permit Section, NPDES Unit <br /> Central Valley Regional Water Quality Control Board <br /> 11020 Sun Center Drive #200 <br /> Rancho Cordova, CA 95670 <br /> Phone: (916) 464-4824 <br /> email: gperreira@waterboards.ca.gov <br /> >>> "Frank Girardi [EH) " <fgirardi@sjcehd.com> 4/12/2010 1:36 PM >>> <br /> Gayleen, <br /> I just received a permit from Condor Earth Technologies for well <br /> construction (MW1S, MW2S, and MW-19S) at the above noted facility. <br /> Prior <br /> to processing this permit, has the RWQCB approved this work based on <br /> Workplan and Time Schedule for Analysis of Background Groundwater <br /> Quality dated March 11, 2009? I have a RWQCB approval letter for <br /> destruction of MW4 so I'm ok to approved that well destruction. <br /> Thanks. <br /> Frank Girardi, Senior REHS <br /> San Joaquin County Environmental Health Department <br /> 600 E. Main Street <br /> Stockton, CA 95202 <br /> (209) 953-7868 (Office) <br /> 4/15/2010 <br />