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DRAFT Staff Report -4- Administrative Civil Liability Complaint Rodney and Gayla Schatz dba Mokelumne Rim Vineyards San Joaquin County In general, the submitted reports do not meet the minimum requirements described in the WDRs. Each of the reports is further described below: i. The Water Balance and Treatment Report was due on 17 June 2004. Staff prepared a 30 August 2004 Notice of Violation, Inadequate Water Balance and Treatment Report for the 24 June 2004 Water Balance and Treatment Report. As submitted, the report consisted of three sentences and did not address the issues required by the WDRs. ii. The Groundwater Characterization Workplan was due on 17 June 2004. The workplan was received on 28 June 2004. Staff prepared a 27 August 2004 Conditional Approval for the workplan. The Discharger submitted a 14 March 2005 Addendum I, Response to Conditional Approval on 1 April 2005. Staff prepared a 5 May 2005 Second Conditional Approval for the workplan. The Discharger submitted a 23 May 2005 Addendum II, Response to Second Conditional Approval Letter submitted on 20 June 2005. Staff prepared a Third Conditional Approval for the workplan. The Discharger submitted an 18 August 2005 Map Submittal, Groundwater Monitoring Wells. Staff prepared a 29 August 2005 Map Submittal correspondence stating the proposed well locations are unacceptable. Staff contacted the Discharger on 19 September 2005 and requested a meeting with the Discharger and the consultant(s)to discuss the technical issues that have not been resolved. In that meeting, the Discharger submitted a workplan that, with a minor addendum, was found acceptable on 26 October 2005. iii. The Land Application Area Improvement Report was due on 13 July 2004. The report was submitted on 14 February 2005. Staff addressed the report in the 23 August 2004 NOV stating the preparations in the land application area do not comply with the WDRs. To date, an adequate report has not been received. iv. The Operation and Management Plan was due on 13 July 2004. The report was submitted on 14 February 2005. Staff addressed the report in the 23 August 2004 NOV stating the O&M Plan is inadequate because it did not address most of the items described in the WDRs. To date, an adequate report has not been received. v. The Groundwater Well Installation Report of Results was due on 15 September 2004. Because the wells have not been installed, an acceptable report cannot be submitted. vi. The Salinity Reduction Study was due on 5 April 2005. The Discharger has not submitted it and has stated in the 12 September 2005 response to the 23 August 2005 NOV,that they feel unfairly singled out for preparation of the study. To date, a report has not been submitted. vii. The Background Groundwater Quality Report is due on 15 December 2005. Although the report is not yet overdue, the Discharger cannot comply with the schedule because at least four quarters of groundwater monitoring are required to prepare the report. Submittal of Self-Monitoring Reports Required by Monitoring and Reporting Program A second issues is the failure to submit self-monitoring reports or the submittal of incomplete self- monitoring reports. Submission of incomplete self-monitoring reports continues to the present, WAStalRObrienTlSan laaqum\Mokelmm Rim Vmcyar&ACL Scpt OAStalf Repott.DOC