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r Mr. Greg Basso -2- 24 March 1988 6. No evaluation of the 'significance of pollution found in ground water, the vadose zone, or surface water is provided in the SWAT Report. The SWAT Report should also describe any remedial measures required to mitigate any threat to water quality. 7. Section 13273 of the Water Code requires that a registered civil engineer, a registered geologist, or• a certified engineering geologist certify that the SWAT Report contains "an analysis of surface and groundwater on, under, and within one mile of the solid waste disposal site to provide a reliable indication whether there is any leakage of hazardous waste" and "a chemical characterization of the soil-pore liquid in those areas which are likely to be affected if the solid waste disposal site is leaking, as compared to geologically similar areas near the solid waste disposal site which have not been affected by leakage or waste discharge. " Such a certification is not in the SWAT Report. In view of these deficiencies, the SWAT Report must be revised and resubmitted. Since monitoring wells 1-10 will have to be sampled again, and in view of the well recovery problems in the past, I suggest that the wells be adequately developed long before sampling. On page 4 of the SWAT Report, the author mentions the need for pump tests to determine aquifer permeabi11ties. If these tests were run ininediately after well development, the data could be used in the revised SWAT Report. This revised report must be submitted to the Regional Board by 1 July 1988. If you have any questions, contact me at (916) 361-5737. TIMOTHY CRANDALL Project Engineer TAC:sg ' cc:. Ms. Carolyn Richardson, California Farm Bureau Federation, Sacramento Mr. Alan Biederman, San Joaquin County Local Health District, Stockton Mr. Jack McCollough, Beta Associates, San Jose Mr. Dan Maglionico, EBA Associates, Orangevale