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MEMORANDUM r CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD - CENTRAL VALLEY REGION 3443 Routier Road, Suite A Phone: (916) 361-5600 Sacramento, CA 95827-3098 ATSS Phone: 8-495-5600 TO: Ton Vorster FROM: Twila Leclerc Senior Engineer Area Engineer DATE: 4 June 1990 SIGNATURE: SUBJECT: DOLE FRESH FRUIT CO./VICTOR FRUIT GROUND WATER MONITORING PROPOSAL I have reviewed Dole's response, dated 31 August 1989, prepared by Tenera, to our comments concerning their groundwater monitoring proposal . Our major concern regarding this proposal is that existing wells are unlikely to be adequately screened to represent the first aquifer. There is no evidence presented which shows these wells meet the objective to represent the uppermost aquifer. A revised proposal must be submitted to address our questions and concerns. The following numbered comments correlate to Dole's numbered responses: 1. The proposed effluent monitoring will include weekly composite samples to be analyzed for pH, total dissolved solids (TDS) , and conductivity (EC) . Standard minerals should also be included in the analysis. Instead of analysis of TDS, we recommend analysis of fixed TDS which only includes mineral content. Samples were proposed to be taken during the 1990 packing season, 1 March to 1 September. Since the packing season has already begun, sampling should begin immediately. We have no objections to Dole's using this data to plan a method for TDS source control . However, Dole should sample more frequently since wastewater changes hourly. 4. Dole' s updated waste discharge requirements should reflect the quantity of wastewater used to irrigate the vineyard. Dole must measure and submit the quantity in gallons per day (gpd) of effluent and well water used for irrigation. 5.a. Dole is planning to abandon the existing, on-site irrigation/monitoring well and install a new one. The new well is proposed to be closer to the vineyard, and still downgrad i ent of the ponds and vineyard, which is a better 'location than the previous well for monitoring purposes. This well should be screened in the uppermost water-bearing zone based on lithology encountered so samples can be taken of the shallow ground water. 5.e. The proposed monitoring well sampling procedure discusses the wells to be sampled, but not the sampling technique. A detailed sampling technique and protocol need to be included in the revised proposal . 5.f. The wells proposed to be used in the ground water monitoring program can be sampled for TDS. However, before we can accept these wells as part of the ground water monitoring program, Dole must show with detailed well logs that samples from these wells can adequately represent the water quality from the uppermost water- bearing zone or shallow aquifer. It is unlikely that these wells only screen the shallow ground water, in which case new monitoring wells will have to be installed. If the direction of local ground water is not consistent with the regional maps, additional wells may have to be installed.