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California Regional Water Quality Control Board <br /> •.4 <br /> Central Valley Region <br /> Robert Schneider,Chair <br /> Winston H.Hickox Gray Davis <br /> Secretaryfor Sacramento Main Office Governor <br /> Environmental Internet Address: http://w .swrcb.ca.gov/- gcb5 <br /> Protection 3443 Routier Road,Suite A,Sacramento,California 95827-3003 <br /> Phone(916)255-3000-FAX(916)255-3015 <br /> 2 October 2002 <br /> Mr. Lynn Forcum <br /> California Natural Products <br /> P.O. Box 1219 <br /> Lathrop, CA 95330 <br /> CONDITIONAL APPROVAL,ADDENDUM TO GROUNDWATER MONITORING WORKPLAN, <br /> CALIFORNIA NATURAL PRODUCTS, LATHROP, SANJOAQUIN COUNTY <br /> I have reviewed the 20 September 2002 Addendum Letter, Groundwater Monitoring Workplan, California <br /> Natural Products, prepared by Kleinfelder, Inc. The addendum was prepared in response to a 21 August <br /> 2002 Regional Water Board Conditional Approval of the 6 June 2002 Groundwater Well Installation <br /> Workplan. The original workplan was prepared in response to Waste Discharge Requirements Order No. <br /> R5-2002-0071, Provision G.2.b,which required submittal of the groundwater workplan. <br /> Staff's conditional approval letter included data on nearby Sharpe Army Depot groundwater elevations. <br /> However, the Kleinfelder submittal does not employ the additional groundwater elevation data provided <br /> by the Regional Board, nor does it clarify groundwater hydrogeology in the site vicinity. Please address <br /> the following comments: <br /> — Kleinfelder's addendum proposes that an upgradient well be installed in one of two well locations for <br /> the 17.6-acre land application area. However, the addendum does not specify which location will be <br /> chosen. By 11 October 2002, submit a revised Plate 5 with a specific groundwater monitoring well <br /> location or add a sufficient number of wells to allow evaluation of groundwater conditions upgradient <br /> and downgradient of land application areas. <br /> — Both of the proposed upgradient well locations are in-line with Wells W-2 and W-4, this alignment <br /> makes interpretation of the groundwater elevation more difficult. The proposed well location shall be <br /> placed in a location that is not in-line with existing wells. <br /> — The addendum recommends reconfiguring the 16.0-acre land application area to prevent wastewater <br /> application in the area of Well L-1. That is acceptable with written confirmation from California <br /> Natural Products that a berm will be installed and wastewater will not be applied within 50-feet of the <br /> well. <br /> — The addendum failed to provide a schedule for implementation of the workplan. California Natural <br /> Products shall install the additional well by 26 December 2002. By 24 February 2002 the well <br /> installation report shall be submitted. <br /> California Environmental Protection Agency <br /> ZORecycled Paper <br /> The energy challenge facing California is real. Every Californian needs to take immediate action to reduce energy consumption. <br /> For a list of simple ways you can reduce demand and cut your energy costs,see our Web-site at http://www.swrcb.ca.gov/mgcb5 <br />