SITE INFORMATION AND CORRESPONDENCE

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Rodney Schatz - 4 - 23 August 2005 3. WDRs Provision G.l.d required submittal of a Land Application Area Improvement Report (LAAIR). The LAAIR was required to show adequate containment exists surrounding the land application area. The report states, "A levee will be used if necessary on the west boundary, east of the railroad tracks." This indicates a containment berm does not exist surrounding the land application area. To date, an adequate report has not been received. 4. WDRs Provision G.l.e required submittal of an Operation and Management Plan (O&M Plan). The 10 February 2005 O&M Plan that was submitted is inadequate because it does not address most of the items described in the Provision G.Le. To date, an adequate report has not been received. Provision G.Le is reproduced below: By 13 July 2004, the Discharger,shall submit and implement an Operation and Management Plan (O&M Plan) that addresses operation of the wastewater treatment and land application facility. At a minimum, the O&MPlan will describe (a) the daily operation and maintenance of the treatment system, (b) the practices used to treat the wastewater within limits specified in this Order, (c) define the land application area, and procedures used for the application of wastewater to these areas to prevent excessive BOD, nitrogen, and dissolved solids application loading rates, (d) the locations o fflow and effluent points, (e) quality control sampling procedures necessary to obtain representative sampling s, (fi maintenance of the land application areas, and(g) the locations of the solid waste disposal areas, methods of disposal, and the daily practices associated with the disposal of the solid waste. A copy of the O&MPlan shall be kept at the facility for reference by operating personnel and they shall be familiar with its contents. 5. WDRs Provision G.Lf required submittal of a Groundwater Well Installation Report of Results by 15 September 2004. A complete monitoring well installation workplan has not been submitted and the wells have not been installed. 6. WDRs Provision G.l.g required submittal of a Salinity Reduction Study by 5 April 2005. The report has not been submitted. 7. WDRs Provision G.Lh required submittal of a Background Groundwater Quality Study Report by 15 December 2005. Because the report was to summarize and analyze groundwater quality over a time period of at least four quarters of consecutive sampling, Mokelumne Rim will not be able to comply with this requirement by the compliance date. This report is considered especially important because the Discharger has elected to discharge wastewater into an unlined pond, increasing the likelihood of groundwater quality degradation. 16 June 2005 R&G Schatz Farms Correspondence Staff has reviewed the 16 June 2005 correspondence requesting clarification on monitoring report inadequacies, wastewater pond size, wastewater pond aeration, and storm water issues. You also requested the name on the WDRs be changed and clarification of the certification statement. All the issues are discussed above with the following exceptions: W AStaQlObrienT$an JoaquinUokelumne Rim Vineyardsi5clmu 2 Aug 05.doc