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MR. BILL DUCKENFIELD 3 1 May 1991 VICTOR FINE FOODS Furthermore, it appears that the LCRS was not tested in 1990 as required in RM&RP No. 90-047. This is a violation of the LCRS testing required in the EESB Monitoring section of RM&RP No. 90--047 which states: "The LCRS shall be tested annually to demonstrate operation in conformance with waste discharge requirements. The results of these tests shall be reported to the Board and shall include comparison with earlier tests made under comparable conditions." DECEMBER 1990 QUARTERLY SAMPLING EVENT: While the ground water data contained a written interpretation and summary, no graphical or tabular summaries were provided to demonstrate that VFF is complying with RM&RP No. 90-047. Review of other ground water monitoring reports submitted in 1990 found that no graphical or tabular summaries were presented in those submittals. The Report summary indicates that VFF intends to reduce the constituents being sampled in the ground water monitoring program. Before VFF can reduce the required sampling constituents or frequencies, VFF must submit a Technical report that a) determines if there is a statistically significant increase over water quality protection standards for each parameter and constituent analyzed and b) demonstrates correlations or trends that supports a reduction in sampling constituents. Once we review and approve this Report, we will revise the monitoring program. VFF should continue sampling as required until notified in writing that changes in the monitoring program are approved. Failure to monitor as required by RM&RP No. 90-047 may result in enforcement action by the Regional Board. QUARTERLY MONITORING REPORT - SOCI: Review of the Quarterly Monitoring Report (QMR) shows that no attempt was made to summarize and interpret data collected by SOCI, which is a violation of RM&RP No. 90-047. Also the QMR contained data collected from June 1990 through December 1990. A quarterly report discussing data collected July through September 1990 was due on 15 September 1991; however, no quarterly report was ever submitted in 1990. The Quarterly Report for October through December 1990 was submitted on 7 february 1991, but was due on 15 January 1991. Quarterly Reports are due on the 15th of the month following the end of the quarter the samples were taken or observations were made. The QMR contained data and a map relating to the lysimeters at VFF. Again, no attempt was made to summarize the data to show compliance or trends that may indicate a problem. On 17 January 1991, we sent VFF an example of an acceptable form to summarize the data. This form may be used to present the data but a written interpretation and summary should also be submitted.