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(_:allitornia t<egionaj water Quality t-ontrot uoaru Central Valley RegionI14& _ <br /> Karl E. Longley,ScD, P.E.,Chair <br /> Linda S. Adams Arnold <br /> Secretai for Sacramento Main Office Schwarzenegger <br /> Environmental 11020 Sun Center Drive#2O0. Rancho Cordova.California 95670-6114 Governor <br /> Protection Phone(916)464-3291 •FAX(916)464-4645 <br /> httpIN vvaterboards.ca.-lov/centralvalley <br /> To: Cori Condon FROM: Kathryn L. Dominic <br /> Senior Engineering Geologist Engineering Geologist <br /> Site Cleanup Unt Site Cleanup Unit <br /> DATE: 21 March 2008 SIGNATURE: <br /> SUBJECT: COMBINED WORK PLAN — SOURCE AREA INVESTIGATION, POND <br /> DISCHARGE PUMP AREA AND PIPING INTEGRITY, AND SURFACE RELEASES, <br /> J.R. SIMPLOT, 16777 HOWLAND ROAD, LATHROP, SAN JOAQUIN COUNTY <br /> In its correspondences dated 1 August 2007, the Regional Water Quality Control Board <br /> (Regional Water Board) made specific requests for information to be included as part of the <br /> Combined Work Plan (Work Plan), dated September, 2007. 1 have reviewed the Work Plan <br /> and have the following comments. <br /> GENERAL <br /> 1. Page 9 — The discussion of vertical extent notes a significant downward vertical hydraulic <br /> gradient accentuated by pumping activities in association with cleanup by Occidental <br /> Chemical (Oxychem) at the extraction wells west of the J.R. Simplot operations. The <br /> Work Plan states that pumping may draw contaminants from the J.R. Simplot releases <br /> into the deeper aquifer zones. We recommend that J.R. Simplot and Oxychem <br /> coordinate well sampling and monitoring events to the extent practicable in order to <br /> confirm whether such downward migration is occurring. Forthcoming revisions to the <br /> Monitoring and Reporting Program for J.R. Simplot will re-state this recommendation. <br /> 2. Section 5.7 — Sample Analyses. Please confirm in an addendum to the Work Plan that <br /> all environmental samples collected under this Work Pian will be submitted to a <br /> California-certified analytical laboratory that follows US EPA standard methods and <br /> protocols (see comment #13 below). <br /> 3. As required by Title 23 and Title 27 of the California Code of Regulations, all analytical <br /> results, as well as reports and well data, generated in this and future investigations must <br /> be electronically uploaded to the State Water Board GeoTracker database. <br /> 4. Section 5.7 — Sample Analyses. Please provide information explaining how J.R. Simplot <br /> will establish background levels of nitrate, ammonium sulfate, and other constituents of <br /> concern in soils and groundwater. This is critical to establishing cleanup goals for the <br /> impacted areas at the site (see comments # 8 and #23 below). <br /> California Environmental Protection Agency <br /> f}• Reef letr leper <br />