SITE INFORMATION AND CORRESPONDENCE_FILE 1

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Mr. Timothy VanDomelen - 2 - 9 May 2008 J.R. Simplot, Lathrop, San . �quin County discussed by telephone on 2 April 2008, the document could not be located in either Simplot's or the Regional Water Board's files. Please provide a discussion of the concentrations and trends in CDCs relative to the past 5 years in the next quarterly report, due 1 August 2008. 3. All laboratory chemical analyses for environmental monitoring purposes must be performed by a California-certified laboratory. Any additional chemical analyses performed by J.R. Simplot's in-house laboratory for the locations specified in the MRP shall also be reported. 4. MRP Section C.3 requires continuous measurement of flow rate in the leachate monitoring system, and reporting of these data quarterly. Although the table on page 4 of Part 3 of the Annual Report shows "gallons pumped" from the leachate collection and recovery system (LCRS) for a single date, it is unclear how much leachate was generated every quarter. The data presented in the Annual Report are not sufficient to make determinations of when and the rate at which leachate was generated from the ponds in 2007. The Annual Report should provide a narrative summary of the leachate amounts, flow rates, a figure showing the locations of sumps and monitoring points, and a description of leachate disposal (with disposal documentation provided in an appendix). If a flow rate cannot be determined because no leachate is being generated, the report text should state that condition. 5. MRP Section C.3 requires analysis of leachate on an annual basis for Chemical Oxygen Demand (COD), minerals, metals, and volatile organic compounds (VOCs). The Annual Report does not provide all of these data in a concise manner, and presents no information or interpretation in the text about the detections noted. We request separate tables showing analytical results for each area being monitored: • Leachate. • LCRS. • Groundwater. • Process water ponds. • Stormwater pond. • Vadose zone. Summaries of analytical results should be compiled in tables that show the compounds, sample location identification, sample dates, detection limits for each analyte, and units of measurement. The text should mention explicitly any points that could not be sampled, and notes in the tables should indicate why a constituent was not sampled or not analyzed. 6. MRP Section CA requires annual analysis and reporting of pollutants in the LCRS. Currently, Simplot appears to be collecting these data one to four times per year, based on the tables provided on pages 69-82. Samples should be collected annually when liquids are present in the ponds, in order to determine if leakage is occurring. This will provide a better understanding of which ponds may have leaks in their primary liners. If a sampling point is empty, your tables should show the sampling date and location, and a notation indicating that the pond was empty, rather than omitting the entry altogether.