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California Regional Water Quality Control Board <br /> Central Valley Region _` ' <br /> �., <br /> ` Karl E. Longley,ScD, P.F.,Chair <br /> Linda S.Adams Arnold <br /> Secretor yfor Sacramento Main Office ������� arzenegger <br /> Ertrtrormterrta/ 11020 Sun Center Drive 11200.Rancho Cordova.California 95670-6114 WU '(�'J/�;o�.ernor <br /> PrrOlUne n Phone(916)464-3291 •FAX(9)6)464-4645 <br /> http.//n�,N�.%%atcrboards.ca.gov/centralvallec <br /> MAR 2 5 2008 <br /> ENVIRONMENT HEALTH <br /> 21 March 2008 PERMIT/SERVICES <br /> Mr. Tim Van Domelen <br /> Manager, Environmental Health, Safety, and Security <br /> J. R. Simplot Company <br /> 16777 Howland Road <br /> Lathrop, CA 95333-0198 <br /> COMBINED WORK PLAN— SOURCE AREA INVESTIGATION, POND DISCHARGE PUMP <br /> AREA AND PIPING INTEGRITY, AND SURFACE RELEASES, J.R. SIMPLOT COMPANY, <br /> 16777 HOWLAND ROAD, LATHROP, SAN JOAQUIN COUNTY <br /> The Central Valley Regional Water Quality Control Board staff has received the Combined <br /> Work Plan (Work Plan), prepared by Geomatrix Consultants, Inc., on behalf of J.R. Simplot, <br /> dated September, 2007. We appreciate the opportunity to provide comments on this Work <br /> Plan, which includes the following submittals: <br /> • A completion report for a surface release caused by an auto accident in February <br /> 2006; <br /> • Spill documentation for recent releases in the Process Water Release Area, the UN- <br /> 32 Tank Area, and the Ammonium Sulfate Solution Release Area; and the Pond <br /> Discharge Pump Area and Piping Inspection Report (Appendices A through D, <br /> prepared in-house by J.R. Simplot); and <br /> • A Feasibility Study Plan to address monitoring and cleanup of impacted soils and <br /> groundwater in the area of the surface impoundments. <br /> Based on our review of the Work Plan and our current understanding of the issues at this site, <br /> we have the following comments regarding site investigation activities. Additional detailed <br /> comments are provided in the attached memo. <br /> The Regional Water Board has concerns about the process water ponds as a past and <br /> ongoing source of pollutants to groundwater. Even with the large amount of data collected to <br /> date, it is not possible for us to discern whether the ponds or their associated piping continue <br /> to leak. Consulting expertise is needed to evaluate the effectiveness of the ponds and the <br /> integrity of their liner and piping systems in preventing future releases, based on available <br /> data. If additional data are needed, your consultants should provide recommendations <br /> appropriate for filling any data gaps. This may benefit J.R.Simplot by reducing effort and costs <br /> associated with these tasks. <br /> California Environmental Protection Agency <br /> *G• Rc,vc/ed Paper <br />