SITE INFORMATION AND CORRESPONDENCE_FILE 1

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MONITORING AND REPORTING PROGRAM NO. 97-229 - 2 - J.R. 2 -J.R. SIMPLOT LATHROP FACILITY SAN JOAQUIN COUNTY 97-229. Failure to comply with this program, or with the Standard Provisions and Reporting Requirements dated September 2003, constitutes noncompliance with the WDRs and with Water Code Section 13304, which may result in the imposition of civil monetary liability. Water Quality Protection Standard The Water Quality Protection Standard shall consist of the constituents of concern, concentration limits, and point of compliance for the Class II surface impoundments. Concentrations of Constituents of Concern in waters passing through the Point of Compliance shall not exceed the Concentration Limits established in this MRP. Constituents of Concern The Constituents of Concern (COCs) include all the waste constituents, their reaction produc , and hazardous waste constituents that are reasonably expected to be in or derived from waste contained at the facility. For each impoundment the Constituents of Concern must comply with Title 27 Section 20395. All groundwater, surface impoundment, unsaturated zone, and leachate samples will be analyzed for the Constituents of Concern shown in Table 1. The concentration limit for one Constituent of Concern, phosphate, shall be the natural background concentration as determined by the Discharger using appropriate statistical methods. The Discharger shall determine the natural background concentration of phosphate within120 days of the effective date of this order. Concentration Limits For the purposes of this MRP, the concentration limits for Constituents of Concern in groundwater are those limits provided in J. R. Simplot's Corrective Action Work Plan (June 2005) or the Water Quality Objectives established in the Water Quality Control Plan for the Sacramento River and San Joaquin River Basin, Fourth Edition (hereafter Basin Plan), for analytes for which J.R. Simplot has not determined a concentration limit. Concentration limit are shown in Table 1. Concentration limits from the Corrective Action Work Plan for inorganic compounds are based on an upper confidence interval calculated by parametric analysis. In the case of dissolved metals, the concentration limits shown are either historical maximum concentrations in background monitoring well LP-7, or laboratory practical quantitation limits based on analyses performed in 2005. Samples collected from the Class II surface water impoundments, leachate collection system, unsaturated zone, and stormwater impoundment are not subject to concentration limits shown in Table 1, which are specific to the waters passing through the point of compliance. J. R. Simplot is required to re-evaluate and, if necessary, update the concentration limits shown in Table 1 and their statistical methods annually, based on newly collected data, and to present this information in their annual report.