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IiYK 1.5 dbU'1 i� �=r rrt �.nu r�Rry in ivn �v„- cn�.w-n,o ii. -.rte Mr_PatMitchell 4 _ a ' r nr.1.3 Marcii2001 .. California Natural Products y 7. By 11 June 2001, the Discharger shall submit a WastewatecApplicattna.Plan. The Wastewater: Application Plan shall describe how the wastewater will be applied in compliance with the ' 21 February 2001 Revised Tentative Waste Discharge Requirements; shall address all land application areas, including the landscaped area; and shall describe wastewater application procedures to be implemented during periods of inclement weather. For the landscaped area,the ' Plan shall specifically address bow the wastewater shall be applied such that there will be no runoff. The Wastewater Application Plan shall be prepared under the supervision of a California Registered Engineer. ' 8. By 11 June 2001, the Discharger shall submit a Cropping Plan. The.Cropping'Plan shall be prepared by an agronomist, shall identify the crops to be grown, present nitrogen removal calculations, and crop cutting(harvesting procedures. The report shall evaluate the effect of applying ' wastewater to the land application areas,including the landscaped area. For each area, the report shall evaluate the present application rate and the Discharger's proposed application rate. The evaluation shall include a description of the irrigation schedule, potential crop problems,water usage ' of recommended crops, evapotranspiration rates, infiltration rates,planting/harvesting schedules, and the long term impact to soil and quality of the wastewater application. The report shall also address the loading rates of total dissolved solids, sodium, chloride, BOD, and nitrogen on the land. Salt taccumulation in soil and potential groundwater impacts must be addressed 9. By 30 July 2001,the Discharger shall submit a Groundwater Well Installation Report consistent . with the requirements described in the attached guidance document. The report shall be prepared under the supervision of a California Registered Engineer or Geologist. Completion of the above reports is the first step toward correcting the many problems that have been identified at the site. While we hope to work cooperatively with California Natural Products,please remember that failure to submit the above reports, or submittal of incomplete reports,is also subject to ' enforcement actions. _ Revised Monitoring and Reportine Program California Natural Products has been monitoring its wastewater under the Monitoring and.Reporting ' Program (MRP) adopted with WDRs No. 98-223. This MRP is inadequate and the tentative WDRs contained a revised MRP. During the meeting with staff on 26 February 2001, California Natural Products discussed its minor comments and concerns about this MRP. Most of those concerns have ' been addressed, and the Executive Officer has now signed the updated-MRP, Your copy is attached to this letter, and California Natural Products is directed to immediately.implement.the_revised monitoring requirements. The April 2001 monthly monitatinR report should contain this`additional information. We wish to emphasize again that California Natural Products is in serious violation of its WDRs, and that during this delay in hearing the new.WDRs you must take every possible step to comply with the provisions of WDRs No. 98-223. Wastewater may not be applied to the landscaped area,. as this is , not authorized in the current WDRs. Please note that failure to comply with the existing WDRs may lead to enforcement actions. - r Y .