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J.R. Simplot - 5 - 21 March 2008 <br /> Lathrop, San Joaquin County <br /> 25. Section 6 — Feasibility Study. The Work Plan's Section 6 provides an outline for an FS, <br /> stating that the FS will be performed upon completion of the proposed scope of work. <br /> We concur with this approach but add that progress toward an FS should not depend on <br /> conclusion of all site characterization efforts. An interim remedial action may be prudent <br /> to address the multiple release areas and to prevent future releases. Please provide a <br /> Work Plan for an interim remedial action, and provide a defined strategy and critical path <br /> for completing proposed final remedial actions. <br /> 26. We appreciate J.R. Simplot's efforts in compiling the requested information and <br /> preparing the Work Plan. We request that J.R. Simplot provide copies of all future <br /> cleanup and monitoring reports to Oxychem (Glenn Springs Holdings, Inc.) going <br /> forward. Similarly, we have requested that Oxychem provide their reports to J.R. <br /> Simplot. <br /> Please prepare and submit a Work Plan addendum addressing these comments by 21 April <br /> 2008 and include the following: <br /> • A plan for sampling of soil and groundwater to develop facility-wide background <br /> concentrations for ammonium, general minerals, and TDS; <br /> • Maps showing the locations of pond lysimeters and a plan for evaluating whether <br /> pond liners are preventing new releases; <br /> • Collection of groundwater grab samples at all soil boring locations; <br /> • Figures clearly identifying proposed soil boring locations in the UN-32 Tank Area, <br /> the Ammonium Sulfate Release Area, and the Process Water Release Area; <br /> • A step-out protocol for determining in the field whether additional sampling is <br /> warranted to complete horizontal and vertical delineation of impacts; <br /> • Analysis of a select number of soil samples in each release area with the Waste <br /> Extraction Test to evaluate leachability of pollutants and their potential to impact <br /> underlying groundwater quality; <br /> • A commitment to evaluate all data gathered from the facility in a comprehensive <br /> and integrated approach; and <br /> • A Stormwater Pollution Prevention Plan. <br /> K.D\JR SimplotTorrespondence\Combined Work Plan Comments dor <br />