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0 • <br /> California Regional Water Quality Control Board <br /> Central Valley Region <br /> Terry Tamminen Robert Schneider,Chair Arnold Schwarzenegger <br /> Secretary jar Sacramento Main Office Governor <br /> Environmental Protection Internet Address: hap://www.swrcb.ca.gov/—rwgcb5 <br /> 11020 Sun Center Drive,#200,Rancho Cordova,CA 95670-61 14 D E C <br /> Phone(916)464-3291 •FAX(916)464-0780 - <br /> JAN 2 9 2004 <br /> 27 January 2004 ENVIRONMENT HEALTH <br /> PERMIT/SERVICES <br /> Mr. Lynn Forcum <br /> California Natural Products <br /> P.O. Box 1219 <br /> Lathrop, CA 95330 <br /> CONDITIONAL APPROVAL OF GROUNDWATER MONITORING WORKPLAN, CALIFORNIA <br /> NATURAL PRODUCTS, LATHROP, SAN JOAQUIN COUNTY <br /> I have reviewed the 1 December 2003 Workplan, Additional Monitoring Well Installations, California <br /> Natural Products,prepared by Kleinfelder. The plan was prepared in response to a Provision G.2.b of <br /> Waste Discharge Requirements (WDRs) Order No. R5-2003-0141. After reviewing the workplan, I <br /> have the following comments: <br /> The workplan does not address the evaluation of flow directions at each land application area as <br /> required by the WDRs. The Provision requires the following: <br /> By 4 December 2003, the Discharger shall submit a Groundwater Characterization Workplan. <br /> The workplan shall describe the installation of additional wells to allow evaluation of <br /> groundwater quality upgradient (and out of the influence of wastewater application) and <br /> downgradient at each of the application areas. In addition, the workplan shall include an <br /> evaluation of the groundwater flow directions and monitoring networks at the 29.7 acre, 16 <br /> acre, and 10.1 acre (formerly 17.6 acre) land application areas. Monitoring wells shall be <br /> constructed to yield representative samples from the uppermost layer of the uppermost aquifer <br /> and to comply with applicable well standards. The workplan shall be consistent with, and <br /> include the items listed in, the first section of Attachment C, "Items to be Included in a <br /> Monitoring Well Installation Workplan and a Monitoring Well Installation Report of Results. " <br /> The discussion of groundwater flow directions presented in Section 2.3 is inadequate to allow <br /> evaluation of each of the land application areas. It is unclear why Kleinfelder relied upon published <br /> data that describes regional groundwater flow direction when ten on-site wells exist and considerable <br /> groundwater monitoring has been performed. <br /> To complete the workplan,by 1 March 2004 please submit an evaluation of the groundwater flow <br /> directions at all the land application areas as required by the WDRs. The evaluation shall also contain <br /> a discussion of how the upgradient wells will be maintained upgradient of wastewater application. <br /> California Environmental Protection Agency <br /> co 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 out your energy costs,see our Web-site at http://www.swrcb.ca.gov/mgcb5 <br />