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California Regional Water Quality control Board <br /> Central Valley Region <br /> Robert Schneider,Chair <br /> Alan Lloyd Ph.D. Arnold Schwarzenegger <br /> Secretaryfor Sacramento Main Office Governor <br /> Environmental Protection Internet Address: http://www.swrcb.ca.gov/—rwgcb5 <br /> 11020 Sun Center Drive,4200,Rancho Cordova,CA 95670.6114 n fl D� <br /> Phone(916)464.3291•FAX(916)4644780 W E UE(� <br /> MAR 4 7005 <br /> 3 March 2005 <br /> ENVIRONMENT HEALIH <br /> PERMIT/SERVICES <br /> Lynn Forcum <br /> California Natural Products <br /> P.O. Box 1219 <br /> Lathrop, CA 95330 <br /> INCOMPLETE REPORT OF WASTE DISCHARGE, CALIFORNIA NATURAL PRODUCTS, <br /> LATHROP, SAN JOA QUIN COUNTY <br /> I have briefly reviewed the February 2005 Report of Waste Discharge prepared by Nolte Associates, Inc. <br /> submitted on 5 February 2005 and determined that it is incomplete. As stated in the 18 January 2005 <br /> Regional Board correspondence: <br /> Background groundwater quality at the 10.1-acre land application area has not been <br /> adequately defined; therefore, a groundwater investigation shall be performed to define <br /> background groundwater quality at the 10.1-acre land application area. Definition of <br /> background groundwater quality has been an issue at the land application area since WDRs <br /> Order No. R5-2003-0141 was adopted. Submittals intended to address the issue have been <br /> incomplete and have not adequately addressed the issue... <br /> The RWD will be considered incomplete until the background groundwater quality at the <br /> 10.1-acre land application area is characterized. Furthermore, wastewater may not be <br /> applied to land application areas that are not described in California Natural Product's <br /> existing WDRs. <br /> On 24 February I met with you and Joe Zillis (Kleinfelder, Inc.)to discuss the status of the well to be <br /> located upgradient of the 10.1-acre land application area. The meeting was requested by Mr. Forcum to <br /> allow discussion of the Regional Board's concerns regarding the proposed well locations that <br /> Kleinfelder had presented. The following items were discussed: <br /> • Regional Board staff don't agree with Kleinfelder's interpretation of the groundwater contours as <br /> presented in numerous reports and summarized in the 17 August 2004 Request to Use W-4 As <br /> Upgradient Groundwater Monitoring Point report prepared by Kleinfelder. I explained that staff <br /> believed a groundwater mound existed at the 10.1-acre land application area that was not <br /> adequately evaluated by Kleinfelder. I provided copies of staff s evaluation of some of the <br /> groundwater elevation data for their consideration when evaluating groundwater elevation data. <br /> California Environmental Protection Agency <br /> aZd Recycled Paper <br /> W dSutAObrienTSen laequin\GI_Nat_Produns\Foram 24 Feb OS.dw <br />