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California Agional Water Quality control Board <br /> Central Valley Region <br /> Winston H.Hickox <br /> Robert Schneider Chair 'gid <br /> Secretaryfor Gray Davis <br /> Environmental Sacramento Main Office Governor <br /> Internet Address: http://www.swrcb.ca.gov/—mgcb5 <br /> Protection 3443 Reader Road,Suite A,Sacramento,California 95827-3003 <br /> Phone(916)255-3000•FAX(916)255-3015 <br /> 23 April 2001 <br /> Mr. Lynn Forcum <br /> California Natural Products <br /> P.O. Box 1219 <br /> Lathrop, CA 95330 <br /> CONDITIONAL APPROVAL OF SAMPLING AND ANALYSIS PLAN, CALIFORNIA NATURAL <br /> PRODUCTS, LATHROP, SAN JOAQUIN COUNTY <br /> I have reviewed the 13 April 2001 Sampling and Analysis Plan (SAP), California Natural Products <br /> Facility, prepared by Kleinfelder. The plan was prepared in response to a 13 March 2001 request for <br /> technical reports from the Regional Board. The SAP is generally acceptable, however, I have the <br /> following comments which can be addressed in an addendum letter: <br /> — It should be noted in the SAP that all monitoring shall be performed in accordance with the revised <br /> Monitoring and Reporting Program (MRP)No. 98-223. Any monitoring that is performed in <br /> addition to the minimum requirements shall also be submitted to the Regional Board with the next <br /> regularly scheduled monitoring report in accordance with the Reporting requirements presented in <br /> the MRP. <br /> — Table 6 indicates that California Natural Products (CNP) staff will perform groundwater elevation <br /> measurements for the depth to groundwater measuring events when groundwater samples are not <br /> collected. Please state if the measurements to be collected by CNP staff will be performed consistent <br /> with the SAP and what equipment Will be used by CNP staff. <br /> — Section 6.2 indicates wastewater samples will be collected on a weekly basis. This is more frequent <br /> than what is required by the MRP. It is understood that CNP collects and analyzes wastewater <br /> samples at an in-house laboratory for the City of Lathrop industrial wastewater discharge permit <br /> requirements. Because all the data shall be submitted to the Regional Board, please indicate which <br /> data is generated in a State licensed laboratory. <br /> — The minimum number of tubes for the total coliform test shall be 15. <br /> — Please submit a table that presents the sample holding times for the analytical methods presented in <br /> Tables 1, 4, and 7. <br /> — The use of a hollow stem auger drilling rig in the land application area for the annual soil sampling <br /> requirements is not recommended due to the soil compaction that will result. A Geoprobe drilling <br /> rig, or hand drilled borings will result in less soil compaction and a smaller borehole. <br /> California Environmental Protection Agency <br /> ped Recycled Paper <br /> The energy challenge facing California is real. Every Californian needs to take immediate action to reduce energy consumption. <br /> For a list of simple ways you can reduce demand and cut your energy costs,see our Web-site at http://www.swrcb.ca.gov/mgcb5 <br />