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California4oional Water Quality Cor Board QO <br /> Central Valley RegionKarl E. Longley,ScD,P.E.,Chair <br /> Linda S.Adams Arnold <br /> Secretary for Sacramento Main Office Schwarzenegger <br /> Environmental 11020 Sun Center Drive#200,Rancho Cordova,California 95670-6114 <br /> Phone(916)464-3291 •FAX(916)464 464511 U[E C[E P Y E DDovernor <br /> Prolectron http://www.waterboards.ca.gov/centraivalley <br /> NOV .Q. 1 2007 <br /> 29 October 2007 ENVIRONMENT HEALTH <br /> PERMIT/SERVICES <br /> Ms. Nancy Bishop <br /> Western Farm Service <br /> P.O. Box 6969 <br /> Moraga, CA 94570-6969 <br /> MONITORING AND REPORTING PROGRAM NO. R5-2007-0825, WESTERN FARM <br /> SERVICE, VERNALIS, 35100 SOUTH HIGHWAY 33, SAN JOAQUIN COUNTY <br /> On 25 September 2007, Regional Water Quality Control Board, Central Valley Region <br /> (Regional Water Board) staff transmitted a draft Monitoring and Reporting Program (MRP) to <br /> Western Farm Service for its Vernalis facility. On your behalf, your consultant, GeoSyntec <br /> Consultants, transmitted comments on the draft MRP via an email message dated 2 October <br /> 2007. This letter paraphrases Western Farm Service's comments in bulleted text, and <br /> provides Regional Water Board responses in italics. Monitoring and Reporting Program No. <br /> R5-2007-0825 incorporates the comments and is attached. <br /> • In one of the two upgradient monitoring wells, MW-4, reduce sampling frequency from <br /> semi-annually to annually and remove carbamate/urea analyses from this well. <br /> • Remove all analyses except water level measurements from the other upgradient well, <br /> MW-1. <br /> In these upgradient monitoring wells, the monitoring history shows that there have been no <br /> detections of pesticides, fumigants, or volatile organic compounds in at least seven years, <br /> and ammonium and nitrate have been near the water quality objective. Therefore, <br /> carbamate/urea pesticides may be removed from the analytical suite for MW-4. The <br /> monitoring history of MW-4 includes four years of quarterly monitoring and five years of <br /> semi-annual monitoring. The monitoring frequency for MW-4 may be reduced to annually. <br /> Regional Water Board staff concur that routine monitoring of other constituents in MW-1 is <br /> not required since MW-4 will continue to be used for upgradient water quality. <br /> • In MW-3, reduce sampling frequency for volatile organic compounds from semi-annually to <br /> annually. <br /> Volatile organic compounds have not been detected in this well in the past four years. <br /> Additionally, Western Farm Service has analyzed for 1,2,3-TCP in this well using Method <br /> SRL 524M with a detection limit of 0.005 ug/l for four consecutive monitoring events and <br /> 1,2,3-TCP has not been detected. Therefore, in MW-3, Western Farm Service may use <br /> Method 504.1 for analyses of 1,2,3-TCP and may discontinue the low level analysis. <br /> California Environmental Protection Agency <br /> 01 Recycled Paper <br />