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Item#2 <br /> Table 6 indicates that California Natural Products (CNP) staff will perform groundwater <br /> elevation measurements for the depth to groundwater measuring events when groundwater <br /> samples are not collected. Please state if the measurements to be collected by CNP staff will be <br /> performed consistent with the SAP and what equipment will be used by CNP staff. <br /> Measurements by CNP staff will be performed in accordance with that specified in the SAP. <br /> The methodology will be replicated in an attempt to provide consistent data. As stated on pages <br /> A-5 and A-6 of the SAP, CNP staff will use a conductivity-based water level indicator. <br /> Currently, the commercially-available, conductivity-based indicator used by CNP staff is a <br /> unique design that uses a small flashlight(e.g. MaglightTn that is lowered with the tailcap end of <br /> the light down the hole. The tailcap has a conductivity probe on the bottom, above-which is an <br /> insulator (o-ring), above which is another probe. When lowered into the water the first probe <br /> contacts the water surface. When the tailcap of the flashlight is further submerged, the second <br /> probe comes in contact with the water, and lighting the flashlight. When the flashlight is lit the <br /> graduated tape is measured against the mark on the north side of the top of the PVC casing. <br /> Although the "sounder" used by CNP staff appears technically sound, CNP is in the process of <br /> replacing it with a more conventional water level indicator. The model that is being purchased <br /> by CNP is the same brand that is generally used by Kleinfelder(Slope Indicator). <br /> Item#3 <br /> Section 6.2 indicates wastewater samples will be collected on a weekly basis. This is more <br /> frequent than what is required by the MRP. It is understood that CNP collects and analyzes <br /> wastewater samples at an in-house laboratory for the City of Lathrop industrial wastewater <br /> discharge permit requirements. Because all the data shall be submitted to the Regional Board, <br /> please indicate which data is generated in a State licensed laboratory. <br /> The table on the first page of the Revised MRP under the heading "Industrial Wastewater <br /> Monitoring" does state that a composite sample for BOD analysis is obtained weekly. However <br /> BOD is listed as BODS and there is no footnote at the bottom of the table. However, if the <br /> RWQCB did not intend for the composite to be obtained on a weekly basis, or if we have in <br /> some other way misinterpreted this requirement, we would be happy to make any adjustments <br /> required. <br /> It is understood that the RWQCB wants the data collected under the City of Lathrop permit <br /> reported to them also. This data will be supplied for incorporation into the monthly monitoring <br /> reports. The reports will specify which analysis was done by a State-approved laboratory. <br /> 204587-0 LSAP/2011 L330 Page 2 of 8 <br /> Copyright 2001,Kleinfelder,Inc. May 2,2001 <br /> KLEINPELDER 2825 East Myrtle Street,Stockton,CA 9520.5-4794 (209)948-1345 (209)948-0621 fax <br />