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Mr. Timothy VanDomelen - 2 - 21 March 2008 <br /> We encourage J.R. Simplot to use environmental consultants for report preparation. The <br /> State requires that all reports containing interpretation of environmental data be stamped by a <br /> professional engineer or geologist licensed in California. Data tables, maps, and figures <br /> should be prepared in a manner that allows for interpretation of compliance with regulatory <br /> standards. Data collected and analyzed by J.R. Simplot's in-house laboratory may be <br /> submitted to support the investigations. However, this analytical information may be <br /> problematic if the detection limits are not sufficiently low, leading to interpretation that areas <br /> have greater impacts than they do. <br /> A number of data gaps are not addressed by the Work Plan. Overall, a more integrated <br /> approach to the characterization and cleanup of soil and groundwater throughout the facility is <br /> necessary. It is important to develop an understanding of background levels of TDS, <br /> ammonia, and general minerals for the facility. Additionally, establishment of a permanent <br /> groundwater monitoring network is needed to characterize the pollutant plume(s). A spill <br /> prevention plan and stormwater pollution prevention plan for the entire facility should be <br /> prepared to address potential runoff and future releases. <br /> The Regional Water Board requests that an addendum to the Combined Work Plan be <br /> submitted to address the comments in this letter and the attached memo. This addendum is <br /> due by 21 April 2008. <br /> If you have any questions regarding this correspondence, please contact me at (916) 464- <br /> 1588. <br /> Kathryn L. Dominic <br /> Engineering Geologist <br /> Attachment <br /> cc: Ms. Margaret Lagorio, San Joaquin County Environmental Health Department, <br /> Stockton <br /> Mr. Alan L. Prouty, J.R. Simplot Company, Boise, ID <br /> Mr. Ward Wolleson, J.R. Simplot Company, Lathrop <br /> Mr. Mike Mateyk, Conestoga-Rovers & Associates, Stockton <br /> Mr. Timothy G. Souther, Geomatrix, Fresno <br /> Mr, Nam Baek, Glenn Springs Holdings, Inc., Dallas, TX <br />