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STATE OF CALIFORNIA PETE WILSON, Governor CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD— CENTRAL VALLEY REGION m 3443 ROUTIER ROAD, SUITE A SACRAMENTO, CA 95827-3098 PHONE: (916) 361-5600 FAX: (916) 361-5686 R!E E` I V 7 October 1991 (]'0' E's 0 CT 0 9 1991 ENVIRONMENTAL HEALTH PERMIT�SERVICES Mr. Bill Duckenfield Victor Fine Foods P.O. Box 147 Lodi , CA 95240 QUARTERLY MONITORING SUMMARY (28 AUGUST 1991), VICTOR FINE FOODS, LODI, SAN JOAQUIN COUNTY (CASE# 1430) We have reviewed the 28 August 1991 report titled "Quarterly Monitoring Summary" submitted on behalf of Victor Fine Foods (VFF) by Harding Lawson Associates (HLA) . The intent of this report was a) to demonstrate that a reduction in the number of monitoring wells, sampling constituents, and sampling frequency was justified; and b) to propose to Regional Board staff a new ground water monitoring program. Based on our review, additional analysis of the data presented in the report is required. While the report recommends which constituents should be reduced or eliminated from the ground water monitoring program, it does not state which agricultural or domestic wells should be eliminated from the monitoring program. In our 15 April 1991 meeting, HLA stated that they would submit a proposal that states which domestic and agricultural wells should be eliminated from the current monitoring program (see Attachment 1) . Any recommendation to reduce the number of wells or samples collected in the monitoring program should be accompanied with a rationale and supporting technical documentation. Except for water level elevations measured in January 1991, no data were submitted for ground water quality or water level elevations for the first eight months of 1991 . In a 2 May 1991 letter, Nolte Associates state that quarterly monitoring reports submitted by HLA would verify the EC to TDS ratio of 1 .5. While HLA stated that there were correlations between electrical conductivity (EC) , total dissolved solids (TDS) , and other constituents of concern, no statistical analysis was conducted to demonstrate that such a correlation exists or that a reduction in the ground water monitoring program is justified based on this correlation. The comparison of ratios of two constituents by inspection is not acceptable. In our 15 April 1991 meeting, we requested a capture zone analysis that determines the effectiveness of the ground water extraction and cleanup program. No capture zone analysis was presented in the Quarterly Monitoring Summary. The nitrate contours correspond to lower pressure areas or cones of depression in the A and B zones. No discussion was made regarding the influence of the two extraction wells. Based on the increased levels of chlorides and elevated levels of EC and TDS in the C zone, it does not appear that the extraction wells have much influence in the C zone.