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California *egional Water Qualitytiontrol Board 'o P Central Valley Region ,?r Robert Schneider,Chair '" Terry Tamminen Arnold Schwarzeneggei Secretaryfor Sacramento Main Office Governor Environwntal Protection Internet Address: http://w .swrcb.ca.gov/—mgcb5 11020 Sun Center Drive,#200,Rancho Cordova,CA-956706114 Phone(916)464-3291•FAX(916)464-4780 1 October 2004 Mr. Chris Littlefield Kellogg Garden Products 12686 Locke Road Lockeford, CA 95237 REQUEST FOR TECHNICAL REPORT,KELLOGG GARDENPRODUCTS,LOCKEFORD,SAN JOAQUINCOUNTY Staff has reviewed the 7 September 2004 correspondence prepared by Eco:Logic that addresses contact wastewater quality at the Kellogg Garden Products facility in Lockeford. The correspondence describes changes to the contact wastewater system that will reduce the Total Dissolved Solids (TDS) concentration in the contact wastewater pond. The primary change to the contact wastewater system is the addition of well water directly to the contact wastewater pond. This mixture of pond water will be reapplied to the soil amendments to maintain desirable moisture content in the packaged product for retail sale. Previously, well water was added directly to the soil amendment piles; the new plan will result in lower concentrations of TDS in the contact wastewater pond. However, the actual effect of the new plan is unknown because the anticipated TDS concentrations are based on calculations. To measure actual concentrations, staff prepared a Draft Revised Monitoring and Reporting Program (MRP). The Revised MRP was transmitted to you on 9 September 2004 and comments are due by 15 October 2004. The information that will be collected will be important in evaluating Eco:Logic's modeled contact wastewater quality. The 9 September 2004 Regional Board correspondence required Kellogg to submit an evaluation of the contact wastewater quality and propose changes to reduce TDS concentrations or request to be regulated under the Title 27 program by 29 November 2004. Because Kellogg has proposed changes to the operation of the contact wastewater system, the report required by 29 November 2004 is hereby rescinded; the Contact Wastewater Quality Evaluation Report that is described below will address those issues. By 31 May 2005, Kellogg Garden Products shall prepare a Contact Wastewater Quality Evaluation Report. The report shall present and evaluate contact wastewater quality from the time the Revised MRP is adopted to approximately the end of April 2005. The report shall address contact wastewater runoff quality, well water quality, the amount of rainfall and the resulting contact wastewater runoff, contact wastewater pond quality, and groundwater quality. The report shall include a determination of whether or not the contact wastewater in the pond is correctly classified as designated waste. California Environmental Protection Agency Cd Recycled Paper