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Andrew Keller -2- 20 August 2007 4. The Discharger shall provide a separate section for procedures to be followed in the event of evidence of a release. At a minimum, please include the following: • Definition of evidence of a non -naturally occurring constituent release: - When two non -naturally occurring constituents are above the MDL, or - When one non -naturally occurring constituent is above the PQL. • Notification to the Regional Water Board in the event of evidence of a release: - Immediate verbal notification, and - Certified mail notification within seven days. • Response to a release: Refer the reader to the WDRs Order No. R5-2007-0084 and April 2000 Standard Provisions (Page 14, Section XI et. seq.) for the requirements of a response to a release. Then, provide the Standard Provisions in an appendix. 5. Section 3, Sampling Rationale: Please provide revised tables for groundwater, leachate, and stormwater. The revised tables shall include the parameters, analytic method, and sampling schedule. Then, coordinate the table headings in Appendix A to those in Section 3. For example, the table header in Section 3 refers to 8015B as an "organic compound" while Appendix A has the heading as a "Total Petroleum Hydrocarbon". These same types of discrepancies are found for "inorganic (dissolved)", "general chemistry", and "organic compounds" listed in Section 3. Attachment A (enclosed) provides an example of the content and format that shall be provided in the tables of Section 3. 6. Section 4, Sampling Procedures: High quality chemical data collection is essential in groundwater monitoring and site characterization. The primary limitations to the collection of representative samples include (1) mixing of the stagnant casing and fresh screen waters during insertion of the sampling device; (2) disturbance and re -suspension of settled solids at the bottom of the well when using high pumping rates and raising and lowering the pump and bailer; (3) degassing from the bailer during sample handling and transfer; and (4) introduction of trace organics from the tubing and pump materials of construction. Therefore, the Discharger shall use EPA's "Low -Flow (minimal drawdown) Groundwater Sampling Procedures" (EPA/540/S-95/504, April 1996) for collection of samples. In addition, the Discharger shall prohibit the use of bailers, shall select and define tubing and pump materials to prevent the introduction of organics, and shall define pre -cleaning procedures prior to the use of new tubing, pumps, and collection apparatus. 6. Section 6, Quality Assurance/Quality Control: In the SAP, the Discharger shall require the following information for all monitoring data submittals: • The selected laboratory's DHS certification number • The laboratory reports shall be signed by the authorized representative. • The laboratory shall report any "trace" results, each MDL, and each PQL. • The laboratory shall report all QA/QC data required by the WDRs Order No. R5-2007-0084 and April 2000 Standard Provisions. • Then, please refer the reader to the WDRs (Pages 13 through 19) and the April 2000 Standard Provisions for the complete reporting requirements. 7. Section 8, Reporting: In the second sentence, please state that the monitoring reports will be in accordance with the WDRs and MRP Order No. R5-2007-0084 and the 2000 April Standard Provisions.