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California Degional Water Quality Con*-ol Board <br /> Central Valley Region <br /> Karl E. Longley,ScD, P.F.,Chair <br /> Linda S.Adams Arnold <br /> Set,.elarrfor Sacramento Main Office <br /> E171 r1 unmriucil <br /> 11020 Sun Center Drive#200,Rancho Cordova.California 95670-6114 Schwarzenegger Print,(Nn)I Phone(916)464-3291 •FAX(916)464-4645 Gore 1 nur <br /> http://www.xNaterboards.ca.gov/centralvalley <br /> nF <br /> 9 May 2008 � '�j'_ r <br /> Mr. Tim Van Domelen MM 1 <br /> Manager, Environmental Health, Safety, and Security T }iy <br /> J. R. Simplot Company ENVIRON-MEN' <br /> 16777 Howland Road PERP�1tTISc�\�t�a. <br /> Lathrop, CA 95333-0198 <br /> ANNUAL AND FOURTH QUARTER POND AND TEST WELL ASSESSMENT REPORTS <br /> (2007), J.R. SIMPLOT COMPANY, 16777 HOWLAND ROAD, LATHROP, SAN JOAQUIN <br /> COUNTY <br /> The Central Valley Regional Water Quality Control Board (Regional Water Board) staff has <br /> reviewed the Annual and Fourth Quarter Pond and Test Well Assessment Report (Reports). <br /> The Reports are required by Monitoring and Reporting Program (MRP) 97-229. The data <br /> sets for the vadose zone, leachate collection and recovery system (LCRS) for the surface <br /> impoundments, and leachate lack maps and other interpretive information regarding impacts <br /> to groundwater. Therefore, it is not possible to determine whether the surface impoundments <br /> are continuing to release pollutants to the groundwater. The MRP requires interpretation and <br /> graphical presentation of the data in maps. The Annual Report should be organized and <br /> formatted to present site data clearly and concisely for each of the areas of concern; present <br /> interpretations of the data; document how conclusions were drawn; and present the data to <br /> support the conclusions. <br /> I have comments on the Annual Report based upon a review of the document against the <br /> current MRP requirements. The Annual Report is not in full compliance with the requirements. <br /> Because the format and presentation of the quarterly reports are similar to the Annual Report, <br /> by extension, quarterly reports are likely to be out of compliance as well, in their current <br /> format. Until such time as the MRP can be revised, J.R. Simplot must comply fully with the <br /> current MRP's requirements for data collection and reporting. No revision of the 2007 Annual <br /> Report or the First Quarter 2008 report is needed based on the following comments, but all <br /> reports going forward should incorporate the necessary changes. <br /> 1. The MRP requires that monitoring reports be generated and signed by licensed <br /> professional geologists and/or engineers who have expertise in creating these <br /> documents. J.R. Simplot has been advised repeatedly in regard to this matter since <br /> 2000. <br /> 2. MRP Section BA requires submittal of a Constituent of Concern (COC) 5-year report. <br /> The last COC 5-year report that the Regional Water Board has on file is from 2000. A 5- <br /> year report should have been produced in 2005 per the requirements; however, as we <br /> California Environmental Protection Agency <br /> 0117 Recyc le(l Paper <br />