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California Regional Water Quality Control Board <br /> Central Valley Region <br /> Steven T.Butler hair <br /> Winston H.Hickox �a.. 112 I Gray Davis <br /> Secretaryfor Sacramento Main Office Governor <br /> Environmental Internet Address: http://www.swrcb.ca.gov/—rwgcb5 <br /> Protection 3443 Routier Road,Suite A,Sacramento,California 95827-3003 <br /> Phone(916)255-3000•FAX(916)255-3015 <br /> 2 January 2001 <br /> VIA FACSIMILE <br /> Mr. Doug Stidham, City Engineer <br /> City of Escalon <br /> 1854 Main Street <br /> Escalon, CA 95320 <br /> INADEQUATE GROUNDWATER WELL DISINFECTION WORKPLAN ADDENDUM, CITY OF <br /> ESCALON WASTEWATER TREATMENT PLANT, SAN JOA QUIN COUNTY <br /> I have reviewed the 26 December 2000 "Work Plan Addendum: Disinfection of Groundwater <br /> Monitoring Wells, City of Escalon - Waste Water Treatment Plant, "prepared by Geological Technics, <br /> Inc. The workplan addendum was prepared in response to the 21 December 2000 Regional Board <br /> review of Geological Technics' well disinfection workplan dated 7 December 2000. The workplan <br /> describes a well disinfection procedure to address elevated coliform concentrations observed in <br /> groundwater monitoring wells at the City's wastewater treatment plant. <br /> The procedures described in the workplan addendum are not approved. lnnplernentation of the <br /> procedures described in the workplan and the workplan addendum are not consistent with standard <br /> sampling procedures and will result in non-acceptance of the analytical results and the potential for <br /> enforcement action including fines. <br /> The process of decontamination is discussed in Lewis Publishers' Practical Handbook of Groundwater <br /> Monitoring(Chapter 15), and the American Society for Testing and Materials (ASTM D 5088-90) <br /> Standard Practice for Decontamination of Field Equipment Used at Nonradioactive Waste Sites. In <br /> addition, Driscoll's Groundwater and Wells - Second Edition discussing bacteriological analysis (p. 623) <br /> states, "The well must be pumped and the piping system flushed out thoroughly to remove all traces of <br /> chlorine before collecting water samples for testing." Future sample events shall not include addition of <br /> residual Clorox, or other disinfection agent to the well prior to collection of the samples. <br /> Before the follow-up sampling is performed,but no later than 9 January 2001, the Discharger shall <br /> provide a complete description of the decontamination procedures that will be implemented to prevent <br /> introduction of chlorine or other disinfectant agent into the wells. If you have any questions on this <br /> workplan addendum review, please telephone me at(916) 255-3116. <br /> 7TIMOT R. O'BRIEN <br /> Waste Discharge to Land Unit <br /> San Joaquin River Watershed <br /> cc: Mr. Mike Huggins, San Joaquin County Environmental Health Department, Stockton <br /> Mr. Raynold Kablanow,Ph.D., Geological Technics, Modesto <br /> California Environmental Protection Agency <br /> :tea Recycled Paper <br />