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/17S© C__ to_1 <br /> California Regional Water Quality Control Board <br /> Central Valley Region <br /> Robert Schneider,Chair <br /> Terry Tamminen Arnold Schwatzeo <br /> Secretmyfor Sacramento Main Office Governor <br /> Environmental Protection Internet Address: http://www.swrcb.ca.gov/—mgcb5 <br /> 11020 Sun Center Drive,#200,Rancho Cordova,CA 95670-6114 <br /> Phone(916)464-3291 •FAX(916)464-4780 <br /> 15 July 2004 RECE INED <br /> JUL 15 2004 <br /> Mr. Lynn Forcum ENVIRONMENT HEALTH <br /> California Natural Products PERMIT/SERVICES <br /> P.O. Box 1219 <br /> Lathrop, CA 95330 <br /> HYDROGEOLOGIC EVALUATIONREVIEWAND REQUEST FOR WATERBALANCE, <br /> CALIFORNIA NATURAL PRODUCTS, LATHROP,SAN JOAQUIN COUNTY <br /> I have reviewed the 20 May 2004 Hydrogeologic Evaluation of Groundwater Conditions, California <br /> Natural Products, prepared by Kleinfelder. The plan was prepared in response to the Regional Board's <br /> 7 April 2004 Conditional Approval letter. The workplan was originally prepared for Provision G.2.b <br /> of Waste Discharge Requirements (WDRs) Order No. R5-2003-0141. After reviewing the <br /> Hydrogeologic Evaluation, I have the following comments: <br /> • Staff do not agree with the report's conclusion that Well W-5 is an appropriate upgradient well <br /> for the 10.1 acre land application area. Well W-5 is located downgradient of the 10.1 acre land <br /> application area in Kleinfelder's groundwater elevation contour maps. <br /> • In general, staff do not agree with the interpretation of groundwater flow direction as presented in <br /> the Hydrogeologic Report. Staff's interpretation indicates a groundwater mound exists in the <br /> 10.1 acre land application area and Well W-5 is downgradient of the land application area. <br /> • The report does not describe the presence of an unlined irrigation canal located east of the 16 acre <br /> land application area. The presence of the canal can have significant impact on interpretations of <br /> groundwater quality and flow direction. <br /> • The report does not present an analysis of chemical concentration trends. Such an analysis can be <br /> useful when considering if a well is located downgradient of a source area. <br /> Despite the incomplete nature of the Hydrogeologic Evaluation report,because California Natural <br /> Products is planning to cease wastewater discharges to the 10.1 acre land application area, further study <br /> of the adequacy of Well W-5 is suspended. Future concentration trends of W-5 may be used to <br /> determine if wastewater application has degraded groundwater quality. <br /> The proposed sale of the 10.1 acre land application area will decrease the total acreage of land <br /> available for wastewater disposal. The 10.1 acres of land was included in calculations on the <br /> wastewater application capacity when the WDRs were updated last year; sale of the land may result in <br /> California Environmental Protection Agency <br /> Qtl 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 />