PROPOSED ACTION PLAN/WELL HEAD PROTECTION PLAN FOR NITRATE IN AGUA DULCE GROUNDWATER

comments and data on this proposal

Howard Carlips response to Smith's Proposal

9-2-97 This is the proposal of the Lillian Smith committee to California Regional Water Quality Control Board (CRWQCB) as it was receive under a Public Records Act request. Smith refused to provide a copy to the community. It was then scanned and placed on the web in on 7-12-97

Smith published a portion of the document in her "early July edition". We have marked the index. Of the 27 chapters she only published 5 or 18%. As she plans to get this approved by the CRWQCB on August 8, the community will only see about 36% before Smith commits the community to this costly farce. This plan is designed to allow growth, paid for by the existing residents, with her required well and septic upgrades. While she claims it is all Volunteer, then why all the task forces and all the data she demands, including confidential County data on your well and septic systems?????

Many of the proposals are the same as I proposed in September of 1996

PROPOSED ACTION PLAN/WELL HEAD PROTECTION PLAN FOR NITRATE IN AGUA DULCE GROUNDWATER

Index

Lillian Smith introductory letter
Kenneth D. Schmidt introductory letter
Introduction
Objectives
Animal Wastes
Data Management
Documentation
Direction of groundwater flow
Fertilizers
Groundwater monitoring
Groundwater Resource Protection
Interpretation of monitoring results
Laboratory Data Deliverables
Laboratory Quality Control Procedures
Natural Sources
Nitrogen load reductions
Other Potential Nitrogen Sources
Public education
Sample Analyses
Sample Collection
Sampling Equipment
Schedule for plan implementation
Septic Systems
Water-Level Measurements
Water Sampling
Well construction practices
Well data

Prepared for: Agua Dulce Town Council Agua Dulce, California

Prepared by Kenneth D. Schmidt and Associates Groundwater Quality Consultants Fresno, California

July 3, 1997

Agua Dulce Town Council Water Stewardship Committee

July 5, 1 997

Board Members and Staff
California Regional Water Quality Control Board Los Angeles Region
101 Centre Plaza Drive
Monterey Park, CA 91754-2156

Dear Board Members and Staff:

Pursuant to Resolution 96-01 1 of the California Regional Water Quality Control Board ("Regional Board"), we hereby submit a revised draft of the Agua Dulce Town Council Water Stewardship Committee ("WSC") Proposed Action Plan/Well Head Protection Plan for Nitrate in Agua Dulce Groundwater ("Plan") as written by the WSC and its California Certified Hydrologist-Consultant Kenneth Schmidt. In so doing, we restate our desire to cooperate with both state and county agencies in taking reasonable steps to deal with nitrates identified in the Sierra Pelona Groundwater Basin.

In light of the fact that this proposed program is ground breaking as a community endeavor and the Regional Board Staff has no experience with which to guide us or its own cooperative effort in this regard, we stress the necessity for a flexible schedule for undertaking the steps outlined in the Plan. The time schedules included in the July 3, 1997, Proposed Action Plan are tentative and may require revision as implementation progresses.

Once the Plan is approved by the Regional Board, the WSC will fully implement it as a volunteer program. We will recruit manpower as needed from a variety of sources including educational institutions and the community and expect that we may find it necessary to formally employ some individuals as data gatherers. We recognize that we will have to continue to raise funds to pay our professional expert advisors and possibly some data gatherers.

We understand that decreasing nitrate loading is a long-term project and that we cannot expect to see significant results of our mitigation efforts for at least several years in an area of nonpoint source elevations in nitrate levels.

Once again the WSC is undertaking this Plan pursuant to the known community consensus to avoid costly infrastructure that would result in destruction of our rural lifestyle and expedite urban development.

A key factor in this proposed community effort still lies in obtaining the cooperation of both California and Los Angeles County agencies for the purpose of obtaining records, approving new technology and enforcing existing laws, including the Agua Dulce Community Standards District (CSD).

The WSC will act with due diligence in any realistic and voluntary steps we identify over time that would help safeguard Sierra Pelona Basin groundwater.

Sincerely

Lillian Smith for the Water Stewardship Committee

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KENNETH D. SCHMIDT AND ASSOCIATES
GROUNDWATER QUALITY CONSULTANTS
600 WEST SHAW. SUITE 250 FRESCO. CALIFORNIA 93704
TELEPHONE (209) 224-441 2

July 3, 1997

Ms. Lillian Smith
Agua Dulce Water Committee
5327 Glenwall Street Agua Dulce CA 91350

Re: Action Plan/Well Head Protection Plan for Agua Dulce

Dear Lillian:

Submitted herewith is the Action Plan/Well Head Protection Plan. I appreciate the input that you! John Cromwell. and D.J. Poehls provided for this plan.

Sincerely yours,

Kenneth D. Schmidt Geologist No. 1578 Hydrogeologist No. 176

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PROPOSED ACTION PLAN/WELL HEAD PROTECTION PLAN FOR NITRATE IN AGUA DULCE GROUNDWATER

INTRODUCTION

There have been several investigations of nitrate in groundwater in Agua Dulce (James M. Montgomery, Consulting Engineers, Inc.! 1982; CH2M-Hill (1989!) and University of California, Riverside, 1996. High nitrate concentrations have been found in water from wells in some areas of Agua Dulce. The California Regional Water Quality Control Board, Los Angeles Region (RWQCB), requested preparation of this plan to address these high nitrate concentrations.

There are two major groundwater areas in Agua Dulce. The first is in the central part of Agua Dulce, where groundwater is present in alluvium. The second is generally located in the higher topographic areas, where the alluvial deposits are either not present or are mostly above the water level. In the second area, groundwater is developed from water in fractures in the crystalline rock (hard rock) About one-third of the 150 or so wells that were sampled in Agua Dulce during 1992-93 had nitrate concentrations exceeding the maximum contaminant level (MCL) of 45 mg/l For perspective, there are believed to be about 1,300 active water supply wells in Aqua Dulce.

The proposed Action Plan/Well Head Protection Plan is presented in the following order:

1. Objectives
2. Nitrogen Load Reductions
3. Well Data
4. Direction of Groundwater Flow
5. Well Construction Practices
6. Groundwater Monitoring
7. Interpretation of Monitoring Results
8. Public Education
9. Schedule for Plan Implementation

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OBJECTIVES
The objectives of this plan are:

1. To develop a long-term monitoring program for nitrate in groundwater of Agua Dulce.

2. To develop a data base showing long-term and seasonal nitrate concentrations in groundwater.

3. To develop, implement ! and monitor the effects of measures to reduce nitrogen loading to the groundwater.

4. To develop enhanced well siting and construction techniques to improve the quality of water pumped from water supply wells.

5. To educate the public about nitrate in groundwater, the factors that influence these nitrate concentrations, and the control measures that can be used to decrease nitrogen loading to the groundwater.

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NITROGEN LOAD ABDUCTIONS

Previous studies in Agua Dulce have indicated that the following four sources of nitrogen are probably the most important: fertilizers, animal wastes (horses, etc.), septic tanks, and natural factors (i.e., outcrops of the Vasquez Formation in the south part of Agua Dulce). Other potential sources, such as in rainfall and atmospheric fallout, have not been indicated to be important in Agua Dulce.

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Fertilizers

There is an extensive amount of literature on nitrate contributions to groundwater from the application of fertilizers. Nitrogen is one of the most important fertilizers for crops and landscaping. However, the application of nitrogen can have a detrimental effect on water quality if applications are not optimally managed. When optimal nitrogen management is practiced, adverse impacts on water quality can be minimized or eliminated. A variety of management practices for the use of nitrogen fertilizers are now available, which can minimize the leaching of nitrate to the groundwater.

Commercial fertilizers, legumes, and manures are types of materials applied or used for fertilizers. Dependence on commercial fertilizers has grown tremendously since the early 1950's. In addition, soil organic matter contributes a variable amount of nitrogen to plants, depending upon the soil conditions. Nitrate in the water that is used for irrigation also contributes some nitrogen. All sources of nitrogen need to be accounted for in a management plan. Leaching of nitrogen from fertilizers can be significantly reduced by accounting for these sources, and matching the nitrogen loading to the nitrogen uptake and losses.

The amount of water applied for irrigation and rainfall, compared to the evapotranspiration, determines the amount of percolating water available for leaching. The amount of available nitrogen (nitrate, ammonia, and organic) regardless of its source (commercial fertilizer, manure, legume, or soil nitrogen), is one of the most important factors affecting leaching of nitrogen. Chemical fertilizers include anhydrous ammonia, various nitrogen salts (i.e. ! ammonium sulfate), and urea. The extent of leaching depends on the type of fertilizer, with nitrate salts (i.e., sodium nitrate! being the most leachable.

Manure is a valuable, cost effective, and readily available nitrogen resource. However, some complications arise when attempting to use manure for fertilizer. Some of these include: vague estimates of manure application rates, extreme nitrogen variability of the manure, variable gaseous losses during storage and application, and uncertainties associated with the proportions available for plant uptake. The organic nitrogen in manure is eventually transformed to inorganic forms. The over-application of manure can cause water quality problems.

Groundwater contamination can occur if applied rates exceed the uptake. Due to the slow nitrogen release from manure, the amount available for leaching at any point in time is limited. However, mineralization occurs after the crop needs are satisfied, and there is the potential for leaching losses during crop dormancy. Storage and handling have a profound effect on the amount of nitrogen in manure by the time it is distributed onto the soil. Volatilization losses are significant, but the lack of understanding of these losses makes it difficult to properly credit the portion of the nitrogen that eventually is applied for fertilizer. Legumes (i.e., alfalfa) mixed with manure significantly increase the available nitrogen for leaching.

The plan would evaluate the amounts and types of nitrogen fertilizers that are used for landscaping and other plants in the area. The approximate square footage or acreage of fertilized areas would be determined, and tabulations and maps of these prepared.

A University of California Extension Service fertilizer specialist would provide advice on water and fertilizer applications to interested parties. A Nitrogen Fertilizer Task Force (NFTF) will be developed under the guidance of the specialist. The NFTF would include community members with specific knowledge of horticultural practices. Records would be maintained of modifications made. It is projected that at least one dozen sites would be selected for pilot projects to improve the efficiency of water and nitrogen fertilizer use. Regular well monitoring would be instituted at the sites, so that the well water contribution of nitrogen can be evaluated, and the impacts of management practices on groundwater quality determined. The action plan would comprise:

1. develop water and nutrient management program
2. Improve nitrogen fertilizer management in Agua Dulce
3. Improve public awareness
4. Research areas of uncertainty and new technologies.

In terms of manure use for fertilizer, the following would be evaluated.

Knowledge of where heavy loadings of manure should be avoided.

Periodic manure application evaluation of current residences.

Educate citizens about better manure management.

Nontraditional manure handling methods, such as comporting, would be assessed from both economic and environmental perspectives.

Basic inventory information, quantities of actual manure, etc., would be developed to better target the educational efforts.

Incentive programs would be developed, training should be provided and technical assistance should be increased, to encourage individuals to adopt and actively implement best management techniques.

Collecting data pertaining to storage, new technologies or product development, and application of manure and fertilizers should be part of the data collection effort.

The NFTF would be responsible for developing the best management practices (BMPs) which are appropriate for the areas' soils, climate, and plant/landscape characteristics. The task force would also emphasize education on the BMPs of fertilizer management. Research is continually providing new information and technology applicable to nitrogen fertilizer management. Procedures and policies would be developed to incorporate new findings into the existing body of accepted BMPs through the NFTP. This group would be responsible for the review of ongoing BMP development and would formulate recommendations to the ADTC regarding the technical aspects of BMP development.

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Animal Wastes

Nitrogen can move into groundwater below outdoor animal holding areas, manure storage areas, fields or landscaped areas with applied manure, and abandoned feedlots. Applications to fields or landscaped areas were considered under the previous category. A soil seal usually develops under many animal-holding areas that are continually used, minimizing the infiltration of water through the soil surface. The seal is developed by both compaction from saturation resulting from urine and pressure incurred from the animals' weight. Saturated conditions in a feedlot surface, coupled with high amounts of organic carbon, make a feedlot surface conducive for denitrification. However, this seal can be broken and some investigations have found nitrate and ammonium moving through the soil profile and reaching groundwater, especially below inactive feedlots. Runoff from active feedlots and subsequent infiltration has also been shown to be an important source of nitrogen in groundwater in some cases.

Areas of known historical and current feedlot or high density animal holding areas will be investigated. For abandoned feedlot situations, manure scraping and removal followed by planting alfalfa and clover, surface cover, or other high nitrogen consuming crops, can reduce the potential for nitrate leaching to groundwater. Such options will be reviewed regarding their economical and technical feasibility. The runoff potential for such areas will also be evaluated.

A majority of the Agua Dulce residents voting in a November 5, 1996 election indicated a willingness to support a voluntary manure removal program. AV. Rubbish of Palmdale is willing to provide separate containers at discount prices to collect manure. Manure is to be kept separate and uncontaminated by any other refuse. A minimum of 40 volunteer families are to be contacted to institute the program. Those already using the services of AV. Rubbish have been solicited to participate in the above mentioned program. AV. Rubbish also has agreed to provide to the Agua Dulce Water Stewardship Committee an accounting of the amount of manure removed from the Agua Dulce area. This will provide a quantifiable mitigation to provide to the RWQCB.

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Septic Systems

Residents in Aqua Dulce households dispose of wastewater into septic systems, which are not intentionally designed to remove nitrogen. Impacts of septic systems on groundwater primarily depend on the nitrogen loading to the aquifer, diluting capacity of the aquifer, and the potential for denitrification in the soil below the system. The diluting capacity of an aquifer is reduced when the density of systems increases. While the use of individual septic tank systems on large lots may not cause a noticeable increase in nitrate concentrations in groundwater, the cumulative impact of multiple drain fields in a housing development with smaller lots may be noticeable. One of the critical factors affecting nitrate concentrations is the average lot size. When average lot sizes are less than one to two acres in a development, where the soils are coarse-grained, and individual wells are used, there is increased potential for higher nitrate concentrations. Other important factors are the amount of recharge from other sources (i.e., rainfall) and the aquifer transmissivity, which controls the amount of lateral groundwater flow. Several different types of septic tank systems have been developed which promote denitrification, resulting in nitrogen removals between 50 and 95 percent. Further testing and evaluation of these systems is needed.

A Septic System Task Force (SSTF) will be established. The focus of this task force will be to evaluate and educate the Agua Dulce community on the best care and operation of septic tank systems. Property owners will be contacted by the SSTF and a survey conducted on an on-going basis. The purpose of the survey will be to compile a database on the number, age, location and type of the septic tank disposal system in relation to nearby wells. The SSTF will also educate and inform the septic system owner of current technologies and the responsibilities of septic system care. The SSTF will also be responsible for evaluating and researching the development of septic systems that can remove nitrogen. Feasible systems should be evaluated for costs of installation and maintenance, nitrogen reduction, and overall system performance. The task force will investigate the policies of State supported research on alternative system testing.

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Natural Sources

The relation of rock outcrops (i.e., volcanic rocks and sedimentary rocks) and soil types to nitrate in groundwater will be further evaluated. First, large-scale maps will be used to plot rock outcrops, soil types, and nitrate concentrations in groundwater, based on the results of on-going and previous monitoring programs. In conjunction with the Enhanced Well Siting and Construction Practices Task Force (EWSCPTF), which is discussed later, vertical differences in groundwater quality related to natural factors will be evaluated. The influence of periodic leaching of natural nitrogen (i.e., during high rainfall events) will be evaluated. Several areas of outcrops of high-nitrogen rocks or soils will be selected for research, and well monitoring would be conducted in some of these. The task force would make recommendations on dealing with natural sources of nitrate. Examples include siting wells in different areas, and developing new wells to exclude water in specific formations which contain natural nitrate.

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Other Potential Nitrogen Sources

If evidence arises during the implementation of this Action Plan/ Well Head Protection Plan that other sources of nitrogen are significant, plans to evaluate and address them would be developed for review by the RWQCB.

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Well Data

Appendix A of the University of California, Riverside, February 1996 report contains a list of wells with State water well drillers reports (Table Al) and a table on sampled wells (Table B1). Figure 3-1 in that report is a small-scale general index map of sampled wells, whereas Plate 2 showed more precise locations of the sampled wells (without identifications). In order to implement this plan, drillers logs in State, County, and UC Riverside files for all wells in Agua Dulce would be provided by the Regional Board. Also, the UC well identification numbers for sampled wells would be placed on a copy of Plate 1 for use by the ADWC contracted hydrogeolocist. The Agua Dulce Community would supplement these logs with any others that can be obtained (including those for wells drilled since the UC Riverside evaluation). In this manner, sampled wells having available construction data would be determined. Once this is done, a well data table would be prepared for use in selecting the wells to be monitored as part of this plan. The 150 or so wells monitored in the UC Riverside study would form the basis for the wells to be selected for monitoring. Other volunteered wells would also be considered. Well files would be maintained by the Community, including drillers logs and other construction information.

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Direction of Groundwater Flow

Knowledge of the direction of groundwater flow is essential in 1) evaluating nitrogen sources for nitrate in water from wells and 2) the effectiveness of various control measures. Few water-level measurements are available for wells in Agua Dulce. Thus the direction of around water flow is not well known. Besides well construction and subsurface geologic data, depth to water and water level elevations are some of the most important parameters than can be determined from the monitoring program. Once water-level measurements are available, then water-level elevation contour maps can be prepared and the direction of groundwater flow can be determined. This and other information allows one to determine which nearby nitrogen sources, if any, are upgradient of a particular well. As part of the monitoring program, depth to the water level will be measured in each well that can be measured. If possible access to the top of the well will be modified, to allow the water level to be measured. When new wells are drilled or pumps pulled in existing wells, access tubes would be installed to allow water-level measurements with an electric sounder (assuming owner approval). These tubes would extend from the land surface to near the pump intake. Also, the elevation of the measuring point would be determined.

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Well Construction Practices

Well construction practices have been demonstrated to exert a significant influence on nitrate concentrations in water pumped from water supply wells. Normally, if the source of nitrate in the groundwater is from a surface source or sources, then higher nitrate concentrations are present in the shallow groundwater. Below the water level, layers of relatively low permeability, such as clay strata, hardpan, or unfractured hardrock, often act as confining beds. These beds act to separate groundwater of different quality at different depths. For example, in hardrock areas, high nitrate groundwater could be present in the shallow weathered zone, but not in fractures at depth, or in the deeper fractures.

Past well construction practices in Agua Dulce have normally focused on obtaining an adequate well yield, as opposed to obtaining low nitrate groundwater. The work during this task will focus on reviewing and compiling a data base on well construction practices, and developing recommendations on improved practices to develop good quality groundwater, where possible. The Enhanced Well Siting and Construction Practices Task Force (EWSCPTF) would be established. Included would be several hydrogeologists and a well driller. Proposed members would be the contracted hydrogeologist, John Cromwell,-D.J. Poehls, and one or two members of the water well drilling industry in the area.

Well records would be reviewed to identify wells that do not have adequate seals and may be in need of repair. The top of selected wells would also be field inspected, with owner approval, and recommendations, if needed, provided to the owner. An education program would be developed on enhanced well maintenance.

During this program, several sites would be selected when new wells are drilled, to use as a pilot test to evaluate vertical differences in groundwater quality. For example, for hardrock wells, water would be air-lifted from each water-producing zone encountered during drilling, water samples collected, and the nitrate concentrations determined. Such information would be used to develop recommended procedures for drilling new wells in high nitrate areas to produce nitrate concentrations below the MCL, if possible. Each new supply well that is developed utilizing this approach in a potential high nitrate area would then be included in the routine monitoring program. In this manner, the long-term viability of this approach would be evaluated.

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Groundwater Monitoring

Approximately 60 supply wells would be monitored on a quarterly basis, to determine fluctuations in nitrate concentrations. The selected wells would have a driller's log available, or at least information on depth and perforated interval. Once every three years, more extensive monitoring would be conducted, probably on about 250 wells. This would be to show geographic and historic trends in nitrate concentrations.

The wells selected for the monitoring program will be based upon the following factors:

Consent of the well owner to provide:

1. access to well for testing for the foreseeable duration of the program (five years or more), and

2. data on their well and the surrounding conditions, to be made at least partially public as part of this study. Note: It may also be possible to allow a limited number of well owners to participate in a confidential manner.

Availability of basic well construction data, such as date of construction, depth of well, length and depth of blank and perforated well casing, casing material, diameter of casing, extent of annular seal and gravel pack, formation log, depth to water, well pumping capacity (gallons per minute, and type of pump.

Previous nitrate sampling results available.

Actively used well, to avoid time consuming purging and delays waiting for stabilization of nitrate prior to sampling.

Geographic distribution of selected wells is to be representative of as much of the Agua Dulce groundwater basin and its subareas (adjoining and contributing canyons valleys, etc.) as possible, including geologic and land use conditions.

Location of well-in relation to septic tank systems, confined animal waste sites, fertilizer applications, and natural sources.

Participation of owners whose wells were included in previous well water quality studies by the Agua Dulce Water Committee, CH2M-Hill, James M. Montgomery Consulting Engineers, Inc.' or the University of California, Riverside.

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Water-Level Measurements

Prior to sampling, the static water level in each well would be measured, where possible. A calibrated electric sounder would be used for these measurements. Also, the approximate elevation of the measuring point would be determined from Geodetic Positioning Systems (GPS). Although initially it may not be possible to measure the water levels in many wells, it is envisioned that water levels will eventually be measured in more of the monitored wells. For example, when pumps are pulled and owners are agreeable, access tubes would be installed. At the time of measurement, it should be noted how long the pump has been off, if this can be determined. It is recommended that the pump be off for at least 15 minutes prior to the measurement. The well number, date, time, and depth to water would be carefully recorded on a water-level measurement form (included in Appendix). Notes would also be maintained on the pumping status of the well prior to the measurement.

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Water Sampling

The primary requirement of the sampling procedures for the Agua Dulce well sampling program is to: 1) meet the needs of the community in terms of determining the concentrations of nitrate in the groundwater, 2) define the extent of the high nitrate concentrations, 3) provide a means to evaluate "natural" versus man-made sources of nitrate concentrations, 4) determine seasonal and long-term variations in nitrate concentrations, 5) evaluate the long-term success of any controls on nitrogen loading that are implemented.

The sampling protocols and quality assurance and quality control (QA/QC) procedures for such a program do not have to be as rigorous as those for groundwater sampling "Superfund" sites. However, the Aqua Dulce well monitoring program sampling should be sufficiently rigorous to generate reasonably accurate! consistent. repeatable, and reliable data.

Many homes have in-line purification systems that would preclude using "tap water" from inside the house as representative of the quality of the well water. Consequently, water that comes directly from the well would be sampled at a point as close to the well as possible.

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Documentation

The steps for sampling each water well are as follows:

Each well should be assigned a unique alpha numeric identification, which when combined with a date and time! would identify where and when the sample was obtained. This identification could minimize personal associations with the data, if desired. These could be the State well designation with a smaller area breakdown (i.e., 5 acres instead of 40 acres), latitude/longitude, UC Riverside I.D. number, or other consistent identification.

2. A standardized form would be developed for use by the sampler to record specific data for each sampling event. A checklist would be developed to be followed by the sampler and would verify that each step was taken and provide a level of quality control. An example is provided in the Appendix.

A "Chain of Custody" form would be filled out by the sampler for a number of samples to document the basic sample data, the handling of the samples, and the transfer of the samples to the laboratory. The "Chain-of-custody" form is a triplicate form. A copy of this form would be returned to the Town Council to document receipt by the laboratory and initiation of analyses within the specified "holding time" for each sample. This form is available from the analytical laboratory. An example is provided in the Appendix.

4. The location of each well will be plotted on a large scale map that shows streets, landmarks, etc.

5. Each well will have a data base that would include basic data on the well and surrounding land use conditions (as described previously) and allow entry of the data from each sampling event. This form will be "hardcopy" and kept securely filed with copies made available as required. All data (this form and chain-of-custody forms, etc.) will be maintained in a secured location.

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Note: To see sampling and collection data, jump to the headings listed below. If you do not, you will not miss anything as it is from the text books

Sampling Equipment
Sample Collection
Sample Analyses
Laboratory Quality Control Procedures

Laboratory Data Deliverables

Laboratory data deliverables will be provided by the laboratory in Level 3 format for all analytical results. Included in the deliverable for all data are:

Final results
Laboratory control standards
Method blanks
Matrix spike/matrix spike duplicates
Surrogate percent recovery summaries
Chain-of-custody record
QC summary forms

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Data Management

The ADWC contracted hydrogeologist will review the field data and results of chemical analyses for reasonableness. If discrepancies are found, they will be discussed with the field and/or laboratory personnel and corrective measures implemented. If necessary, checking, re-analysis of the samples, or revisions in the procedures will be done. Criteria used to judge the acceptability of field data are:

Conformance to applicable data collection requirements
Presence of proper sample identification
Presence and proper completion of chain-of-custody forms
Absence of obvious errors, and
Comparability of data sets.

Field data that do not meet the acceptance criteria will be flagged as "non-conforming" to the acceptance criteria listed above and may have limited use in the data evaluation for that particular monitoring event. A memorandum will be filed in the event that unacceptable field data are encountered during the review process, and procedures undertaken to correct this.

The following data validation procedures will be used to ensure that data received from the laboratory are valid and appropriate for subsequent data evaluation. Each sample delivery group (100 percent of all hard copy data) will be reviewed for the following quality assurance and performance data:

Data package completeness (sample log in and chain-of-custody forms)
Laboratory precision and accuracy data
Lab QA/QC samples (laboratory duplicates)
Field QA/QC samples, such as equipment and trip blanks, and
Field duplicate sample data.

All original laboratory reports will be stored in a secured file cabinet. Original chain-of-custody forms will be treated with similar care. Simultaneously, all laboratory analytical results will be received electronically on diskettes. Quality assurance and control will be maintained through the use of electronic files, reducing the need to manually enter data. The data, including data qualifiers resulting from data validation efforts, will also be incorporated in the data base. Access to the data base will be restricted, and the data base will be used by the appropriate personnel as a central resource for all data.

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Interpretation Of Monitoring Results

A set of topographic maps or aerial photographs of the Agua Dulce Groundwater Basin will be used to develop a basemap to aid in plotting and interpretation of data. An annual report will be prepared by a certified hydrogeologist with expertise in nitrate in groundwater. The monitoring results, interpretation, and the results of the progress of the task forces would be presented. If adequate water-level measurements are obtained, a water-level elevation contour map would be prepared. Flow lines would be added to the map to indicate the direction of groundwater flow. A map would be prepared showing the distribution of nitrate concentrations in sampled wells. For previously sampled wells, a table will be prepared showing historical nitrate analyses, and previous results would be compared to those obtained from this program.

After one year of monitoring, nitrate hydrographs will be prepared to indicate trends in nitrate concentrations for the wells that are sampled quarterly.

Maps will be prepared for each monitored well. The area surrounding the well will be mapped, extending for a distance of approximately 300 feet from the well. Plotted on the map would be the well location, unused or abandoned wells, septic tank disposal system (i.e., leach field), irrigated and landscaped areas, animal holding areas, and rock outcrops or other natural nitrogen source areas. The inferred direction of groundwater flow would also be shown.

Results of the following pilot projects would be discussed:

1. Fertilizer Management Practices (NFTF progress).
2. Septic Tank System Management Practices (SSTF progress).
3. Animal Waste Management Practices.
4. Enhanced Well Siting and Construction Practices (EWSCPTF progress).

Information on vertical trends in nitrate concentrations from drilling of new wells will be presented, as it is obtained. Recommendations for changes in pilot projects or in the groundwater monitoring would be provided.

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Public Education

An Agua Dulce community task force has developed an education program. In addition, the Water Stewardship Committee reports are presented at each bimonthly Town Council meeting. Reports are also given through other community organizations such as the Agua Dulce Civic Association, and are published in the local media. This dissemination of information is intended to raise the consciousness of Agua Dulce residents, and will continue as part of the proposed action plan.

In addition, a centralized source of water related information has been installed in a local merchant's establishment. In a continuing effort to keep public awareness very high on water quality issues and new developments, the Committee is now compiling copies of the tremendous body of information collected over past years. This information will be catalogued and made available to the community during the regular business hours of the cooperating merchant.

Objectives of the public education program are to educate and heighten the awareness of members of the Agua Dulce/Sierra Pelona Basin community (Agua Dulce Watershed Area) of the following:

Basic hydrogeology and specific local groundwater issues, including groundwater supply and demand.

Groundwater use, basic well drilling and installation practices, and including proper well design and operation.

Wellhead protection plan, protection of groundwater quality, and groundwater monitoring.

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Groundwater Resource Protection

To meet the above mentioned objectives the following tasks will be implemented:

Continue presenting information at Town Council Meetings open to the public.
Distribute pamphlets.
Conduct seminars on a quarterly basis including workshops on:
Basic hydrogeology, groundwater quality and supply
Basic drilling techniques, well installation, and proper maintenance of wells and pumps
Proper care and maintenance of septic systems
Wellhead and groundwater protection practices
Recycling and disposal practices
Continue monthly publication of updates of groundwater issues in the local paper.

Appoint several community speakers that would be kept up to date on wellhead protection progress and be available to conduct meetings as required by local groups or organizations requesting information.

Post information at public gathering places regarding waste collection services, recycling, and commercial animal waste disposal options.

Post public signs to make citizens more aware of the groundwater situation.

The education objectives listed above will have been met when the following items have been completed or recorded.

When 800 households have been contacted via mailings.

Seminars are conducted on a semi-annual basis.

Location of a community area to house wellhead protection information and research articles has been secured and is open to the public at regularly scheduled hours.

Semi-annual surveys will be conducted to determine the extent of cooperation and assimilation of information and to form consensus of ways to improve dissemination of information.

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Schedule For Plan Implementation

If the RWQCB comments on the draft plan are received by July 21, a final plan will be developed by August 8, 1997. Implementation of the plan will then begin on August 15, 1997. Table 1 presents the proposed schedule of activities during the first year of the plan. The four components of the nitrogen load reduction programs will essentially be carried out simultaneously. The first six months would primarily involve collecting, compiling, and mapping data, and interpreting this data. Detailed plans for the pilot projects will be developed during the last half of the first year. The draft annual report will be prepared within two months of the end of the first year's activities, including groundwater monitoring.

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