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Addressee - 2 - <br /> Date <br /> c. That beneficial uses of drinking water and agricultural supply were considered to not <br /> exist in shallow groundwater because it exceeded applicable standards for some <br /> constituents; and <br /> d. That the proposed concentration limit for TDS exceeded its MCL, Title 27 prohibits the <br /> Board from setting CLGBs that are greater than MCLS. <br /> The letter concludes that further discussions of concentration limits should be postponed until <br /> completion of additional groundwater investigations. With the completion of the present <br /> Groundwater Assessment Report that time has arrived. If you wish to propose concentration <br /> limits greater than background your revised report should address the issues in the 2 November <br /> 1998 letter. An alternate strategy would be to propose concentration limits based on statistical <br /> analysis of data from the background well MW-5. A revised Water Quality Protection Standard <br /> report should be submitted by 1 September 2000. The September date will allow the inclusion <br /> of data from Second and Third Quarter Monitoring Reports. <br /> 2. A final report for the closure of the lime ponds was due on 15 October 1999. We understand that <br /> removal of the lime wastes has been delayed by weather and other factors. The Groundwater <br /> Assessment Report notes that as of the date of the report approximately 100 percent of the spent <br /> lime has been reused as engineered fill for proposed industrial/commercial areas of the site. <br /> Monitoring and Reporting Program No. 97-204 requires that you monitor on a weekly basis the <br /> quantities of spent lime wastes removed from the lime ponds and remaining waste and report to <br /> the board quarterly. Please submit a report on lime wastes with the next quarterly monitoring <br /> report due on 15 August 2000. In a 2 May 2000 letter, written on your behalf by Kleinfelder <br /> Inc., indicates that a final closure report should be submitted by 1 October 2000. If meeting'this <br /> date becomes a problem please contact board staff. <br /> 3. In the Groundwater Assessment Report and in a telephone conversation, a request has been <br /> made that the monitoring frequency be changed to semi-annually. It has been over a year since <br /> any monitoring has been submitted for this site. Please renew the request after the Groundwater <br /> Protection Standard, the Second Quarter 2000 (proposed submittal date 19 June), and Third <br /> Quarter 2000 Monitoring Reports (proposed submittal date 15 August) have been completed. <br /> This additional data will give board staff a basis to evaluate the need for quarterly semi-annual <br /> monitoring. <br /> If you have any questions please call me at (916) 255-3814. <br /> ROSS ATKINSON <br /> �`� <br /> Associate Engineering Geologist <br /> cc: Mr. Ron Rowe, San Joaquin County Public Health Services, Stockton CA <br /> Mr. Robert Martin, Kleinfelder, hic. Stockton CA <br />