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vCalifornia Regional Water Quality Control Board Winston H.Hickoa Central Valley Region Gray Davis Secretaryfor Robert Schneider,Chair Governor Environmental Protection Sacramento Main Office Intemet Address; http:/Aw .mcb.ca.gov/—mgcb5 3443 Routier Road,Suite A,Sacramento,California 95827-3003 •�L (lr' ii =', i Phone(916)255.3000-FAX(916)255-3015 % - 25 April 2003 APR 2 8 2003 ENVIROUI ENT HEALTH PERMIT/SERVICES Mr. Chris Littlefield Kellogg Garden Products 12686 Locke Road Lockeford, CA 95237 INCOMPLETE R.PPORT OF WASTE DISCHARGE,KELLOGG GARDEN PRODUCTS, LOCKEFORD,SAN JOA Q UIN CO UNTY I have reviewed the November 2002 Technical Support Document, Report of Waste Discharge (RWD)prepared by ECO:LOGIC for Kellogg Garden Products. The document describes existing conditions and a planned expansion to the facility. Please address the following items to complete the RWD: • Please describe how desiccation of the clay liner will be prevented. Because the water balances indicate all contact water evaporates or is reused maintaining product moisture,the storage pond will go dry by the end of September in wet years. In normal rainfall years the pond is likely to go dry earlier. Staff is concerned that the liner will desiccate, crack, and become ineffective. • If the solution to the desiccation of the clay liner is to install a synthetic liner,how will the loss of infiltration affect the water balance? If needed, please submit a water balance that demonstrates adequate storage capacity. • Based on the 15 February 2002 Storm Water Pond Lining report prepared by Neil O. Anderson and Associates, included in Appendix C,the double-ring infiltrometer test was not performed in accordance with American Society for Testing and Materials (ASTM) Standard 3385. Water levels in the inner and outer rings were not maintained within 0.25-inch. If the soil being tested has permeability less than 1 x 10'6 cm/s, ASTM method D 5093 or equivalent should be performed. I have reviewed the December 2002, Groundwater Evaluation Report prepared by ECO:LOGIC which presents proposed locations for replacement groundwater monitoring wells. At this time, Staff does not concur with the proposed well locations and recommend the well replacement program be conducted as part of the update of the Waste Discharge Requirements (WDRs). A groundwater monitoring well destruction and well installation workplan will be required prior to implementation of the groundwater well relocation project. California Environmental Protection Agency Co Recycled Paper The epergy challenge facing California is real. Every Californian needs to take immediate action to reduce energy consumption. For a list of simple ways You can reduce demand and cut your energy costs,see our Web-site at htto'//,N N -sw cb c_a,00virwaW