SITE INFORMATION AND CORRESPONDENCE

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Messrs.Nader Shareghi and Erik Teed-Bose - 2 - 22 March 2005 present agricultural drain monitoring or any other parameter required by the MRP. The report is therefore incomplete. 4. Condor prepared a 6 December 2004 Third Quarter monitoring report, however it only presented groundwater monitoring data and incomplete agricultural drain monitoring. In addition, some agricultural drain samples were not collected because the drain was dry. Regional Board staff provided comments on the agricultural drain issue in correspondence dated 19 April 2004 and 14 June 2004. That correspondence addressed the issue of dry agricultural drains by stating: ...Please redesign the ditch monitoring sample locations and address the 19 April 2004 Incomplete Report comment that stated, "Please add a monitoring location for each of the drains. Because much of the drain maybe dry, selection of a sampling point for each drain can be established based on a description such as, `The furthest upstream a sample can be collected in Drain No. _, but no further upstream than_. ' This approach will require identifying each drain and the area from which a sample can be collected. " Please contact staff to finalize the drain sample locations prior to submitting a revised report. Section 5.1 of the 6 August 2004 Revised Additional Groundwater and Agricultural Drain Monitoring Workplan prepared by Condor stated: Upstream agricultural drain samples will be taken as close to the identified locations (11A, 12A, and 13A) as possible, based on available water in the drains. If insufficient water exists in the drains at the proposed locations, the sample technicians will move downstream (north) until sufficient water is available, even if this is within the reclamation area. Sampling documentation will note the actual location of the upstream sample. There appears to be no reason that the 2A and 11 A agricultural drain samples could not have been collected downstream of the identified sample location. It appears that Condor's field sampling staff did not implement the workplan that was submitted only 47 days earlier. All future sampling events shall conform to the procedures described in the workplan. The fact that an agricultural drain sample was not collected at sample locations 2A and 6A because they were dry should also be addressed as described in the Regional Board's April and June 2004 correspondence(described above). In addition, staff notes that the location of agricultural drain sample 2A is not presented on any of the 6 December 2004 figures and the symbol for sample locations is not consistent between the figures. Please clarify the format and correct the deficiencies prior to submitting future reports. 5. The Third Quarter monitoring report was submitted late. The reporting section of the MRP requires monitoring reports to be submitted "...by the 201h day of the following month." A third quarter monitoring report should be submitted by 20 October of each year. w�Su dcn� iaauinWouwinxovoavmm&i i m 05.&a