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California6gional Water Quality Conel Board Central Valley Region Karl E.Longley,ScD,P.E.,Chair 0 Linda Adams Sacramento Main Office Arnold Secretaryfor 11020 Sun Center Drive#200,Rancho Cordova,California 95670-6114 Schwarzenegger Environmental Phone(916)464-3291 •FAX(916)4644645 Governor Protection http://www.waterbouds.ca.gov/centralvalley 13 August 2007 AUG 1 5 2001 Cary Keaten ENVIRONMENT E�1i R City of Lathrop GES 390 Towne Centre Drive Lathrop, CA 95330 REVIEW OF 28 JUNE 2007 CITY OF LATHROP CORRESPONDENCE, WDRs ORDER NO. R5-2006-0094, CITY OF LATHROP, SAN JOAQUIN COUNTY Staff has reviewed the 28 June 2007 correspondence titled, Response to April 10, 2007 Letter Entitled Incomplete Report, prepared by the City of Lathrop. The letter identifies three issues but only discusses one, the requirement for submittal of a Groundwater Well Project Description Addendum that was included in the 10 April 2007 Incomplete Report correspondence prepared by Regional Water Board staff (attached). As stated in staffs 10 April 2007 letter: The City of Lathrop is currently violating WDRs Order No. R5-2006-0094 because it does not have the groundwater monitoring network required by the WDRs and therefore the replacement wells must be installed as soon as possible. The City's position is that workplans prepared before the Waste Discharge Requirements (WDRs) were adopted change the monitoring well network as defined in Finding No. 62 of the WDRs. However, Finding No. 62 defines how the monitoring well network will be changed in the future to accommodate changes in the wastewater land application system, and in part it states: ...The list below specifies the groundwater monitoring network when this Order is adopted; changes to the specified monitoring network can be made through Executive Officer approved RWERs... The City had ample opportunity to comment on the monitoring network and in fact, did comment on the network listed in the tentative WDRs, which were distributed on 28 July 2006. Comments were received on the tentative Order and a strikethrough underline version of the Order was transmitted followed by the agenda version of the tentative Order on 8 September 2006. Review of the redline version of the Order reveals that four wells originally included in the monitoring network were removed from the network and two more wells were removed from the analytical list at the request of the City. A copy of the changes to Finding 62 presented in the redline version of the Order is attached. Your comments on approval of workplans changing the monitoring well network are not relevant. The WDRs are very clear on how the monitoring well network may be modified. As California Environmental Protection Agency Irl'Recycled Paper