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Mr. Timothy VanDomelen - 3 - 9 May 2008 <br /> J.R. Simplot, Lathrop, San Ji uin County <br /> 4 <br /> 7. MRP Section C. 5 requires calculation of groundwater gradient and interpretation of <br /> groundwater flow direction, and a groundwater contour map updated annually. The <br /> Annual Report does not fulfill this requirement. An excerpt from a 2001 report by <br /> Geomatrix provided on page 2 of the text is not sufficient. Furthermore, this information <br /> must be provided by a California professional geologist. <br /> 8. Data that are collected outside the requirements of the MRP include the following: <br /> MRP requirement Simplot reporting <br /> Weekly measurement of freeboard — Daily <br /> process water pond <br /> Quarterly measurement of minimum Daily <br /> freeboard — stormwater pond <br /> Perchlorate analytical results not Quarterly perchlorate analysis in <br /> required groundwater from LP-1 <br /> Quarterly analysis of minerals and Monthly analysis of minerals and metals <br /> metals — stormwater pond <br /> Although we appreciate your inclusion of these data in your reports, it is J.R. Simplot's <br /> prerogative to maintain this level of data collection or fulfill the MRP's minimum <br /> requirements. <br /> 9. MRP Section C.7 requires analyses of minerals and metals in samples from the <br /> stormwater pond following significant rainfall events. Significant rainfall events should <br /> be highlighted or footnoted in data tables to document the rationale for sample timing. <br /> 10. MRP Section C. 8 requires weekly inspection of the synthetic pond liners. J.R. Simplot is <br /> compiling visual inspection logs as shown in pages 6-7f of Part Three of the Annual <br /> Report. For the sake of completeness, any additional work done during the year to verify <br /> pond integrity (e.g., periodic electronic liner surveys) should be documented in an <br /> appendix to the Annual Report. <br /> 11. MRP Section C.9 requires monthly measurement of field parameters for the vadose zone <br /> monitoring network. These data are presented in tables and charts on pages 83-100. <br /> However, field parameters and samples were not collected monthly for all lysimeters. <br /> For example, there was only one sampling event recorded for the North Pond North <br /> lysimeter in 2007 (p. 83). No explanation for the lack of sampling was provided in the <br /> text or tables. If lysimeters are dry or if there are other reasons why they are not <br /> sampled in compliance with the MRP, explanations must be provided in the Annual <br /> Report. <br /> 12. MRP Section C.9 requires quarterly sampling for TDS and sulfates in the vadose zone <br /> monitoring network. None of the vadose zone monitoring points were sampled <br /> quarterly in 2007, as shown in tables and charts on pages 83-100. If lysimeters are dry <br /> or if there are other reasons why they are not sampled in compliance with the MRP, <br /> explanations must be provided in the Annual Report. <br />