SITE INFORMATION AND CORRESPONDENCE_FILE 1

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J.R. Simplot - 3 - 21 March 2008 Lathrop, San Joaquin County 11 . The locations and construction details of the pond lysimeters should be provided in Figure 6 or in a separate figure. Please provide this information in an addendum to the Work Plan. AUTO ACCIDENT AREA 12. We appreciate the information that describes the incident and the response to the process water release. However, J.R. Simplot must provide an estimate of the volume of the release. Please provide waste manifests for excavated soil disposal and the name and location of the disposal facility, as well as the criteria used for sample collection. Please clarify whether all soil samples collected in 2006 were collected from the bottom of the excavation. Please confirm whether the samples submitted to FGL, Inc., were collected one year later than the original samples analyzed by J.R.Simplot, as shown in Table 3. Please confirm whether the excavation is still open or, if not, what material was used as backfill and its origin. 13. Residual soils exhibited elevated levels of ammonium as a result of the release caused by the auto collision. The proposed five sampling locations are acceptable. However, additional samples must be collected to delineate horizontal and vertical extent. We request subsurface soil sampling in the same depth intervals and for the same chemical analyses as the soil samples proposed for other portions of the site. In addition, a select number of soil samples should be analyzed by the Waste Extraction Test (using deionized water) to evaluate leachability of pollutants, and these data used in an evaluation of potential to impact underlying water quality. UN-32 RELEASE AREA 14. Table 4 documents the differences in detection limits for ammonia between J.R. Simplot's and FGL's analytical techniques. For this reason, all future primary samples analyzed for environmental compliance efforts must be submitted to a California-certified laboratory. J.R. Simplot should consider using its own laboratory for backup or confirmatory purposes only. 15. In the Work Plan text, J.R. Simplot proposes three soil boring locations outside the tank footprint; however, Figure 8 shows three soil sampling locations inside the tank footprint, with different location names from those in the text. Soil sampling locations are indicated to be separate from grab groundwater sampling locations. We request that groundwater grab samples be collected at each of the boring locations to support a more complete understanding of the correlation between impacts to water quality and the concentrations of pollutants in soil. Please provide an updated figure that shows the correct number, names, and locations of soil and water samples. 16. The proposed upgradient or background location in the immediate vicinity of the tank (boring EB-AY) would likely receive subsurface constituents sourced from the waste water ponds. Therefore, background locations outside the active plant are recommended (see comment # 5 above).