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Mr. Benjamin Hall -2 - `+r' 12 July -1999 We have found that these reports are not fully compliant with portions of the current WDRs. We are not requesting that these reports be resubmitted, but we do require that the noted deficiencies be addressed in all future submittals. General comments in common to all the reports are listed first. Comments regarding a specific Monitoring and Reporting Program (MRP) follow. General Comments 1. As stated in the "Standard Provisions and Reporting Requirements for Waste Discharge Requirements" (SPARR), the responsible person signing the document must certify the report using the statement given in the SPARR (bottom of page 4 of the SPARR dated September 1993). A copy of the SPARR is attached for your review. 2. As required by the SPARK, a map or aerial photograph showing the locations of the observation stations, Monitoring Points, and Background Monitoring Points, shall be included with each report. 3. Laboratory reports must indicate the analytical methods used, the Practical Quantitation Level and the Method Detection Level for each analysis. Comments S ecific to MRP 96-075 Surface Impoundments) 1. You are current with your reports through the first quarter of 1999. However, it is noted that the report for the third quarter of 1998 (July through September)was not transmitted until 1 February 1999 and the report for the fourth quarter 1998 (October through December) was not transmitted until 29 April 1999. The MRP for this project indicates that the quarterly reports are due by the 15'b day of the month following the end of the quarter during which samples were collected. Therefore the schedule for submittals of.your quarterly reports are as follows: Quarterly Report Du_ _ e By First Quarter 15 April Second Quarter 15 July Third Quarter 15 October Fourth Quarter 15 January If y_ou cannot adhere_to this schedule please notify usaimmediately. _Failure to.submit reports within_ 30 days of their scheduled due date is a violation which may prompt enforcement actions including administrative civil liabilities. C 2. An annual report is to be submitted and should present tabular and graphical summaries of the data collected during the previous year. The annual report is due by 31 January of each year. No annual report has been received for the 1998 year. Please submit your annual report by 6 August 1999. 3. Laboratory analytical reports for the period 1 July 1998 through 30 September 1998 were not attached to the transmittal dated 1 February 1999 with the exception of the reports for the "Production Water". The laboratory reports should be forwarded to me by 6 August 1999. 4. While flow rate to the ponds is reported, it is not reported for each pond individually. Also it is not indicated which pond is receiving the wastewater..During our inspection on 23 June 1999, you indicated that flow to Ponds A and B is alternated depending on their respective remaining