SITE INFORMATION AND CORRESPONDENCE_FILE 1

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J. R. Simplot, Lathrop -3- 1 August ZUUI San Joaquin County t aboveground piping did not have secondary containment and that it would be difficult to add secondary containment due to concrete piers and pipes that run low to the ground. To contain any future leaks or spills you recommend that dykes be constructed to help prevent the spread of any contaminants. Regional Water Board staff appreciates the -plan to use dykes to secure any leaks; however, we request that in addition to the dykes, J. R. Simplot evaluate a variety of liner systems that can be applied to these areas. As an example, J. R. Simplot could evaluate liner systems such as spray-on liners, plastic sheeting, or pour-on type liners systems. These types of liners may make it possible to seal the soils below and around piers and pipes and allow access for maintenance. Please include this evaluation, the location of the mentioned tunnel on a figure and the requested inspection report in the Work Plan due by 12 September 2007. 3) In the PDPA-PIR J. R. Simplot describes the types of pipes that exist around the surface impoundments; however, you did not assess the integrity of these pipes, or specify whether there was evidence of any leaks from these pipes. Based on the June 2006 EPMIR, the pipes around the surface impoundments were going to be identified and tested for their integrity. The PDPA-PIR does not indicate that integrity testing was performed as proposed, some pipes were not identified, and past operations were unknown. Please provide information on the 12-14 inch diameter PVC pipe that is of unknown origin, assess all piping integrity and determine whether there is or was evidence of any leaks in the underground piping system. The findings of this investigation can be provided in the Work Plan that is requested by 12 September 2007. Based on the preliminary work schedule presented in the EMPIR and the information presented in the EMPA, J.R. Simplot needs to complete by 12 September 2007 the above requested Work Plan that: 1) presents a scope of work that will adequately characterize the releases around the lined surface impoundments, 2) provides information on the pond discharge pump station area, 3) evaluates a variety of liner systems for the pond discharge pipe area and provides the pipes' inspection report, and 4) provides integrity testing and identification information on the underground pipes in the vicinity of the ponds. As committed to in the EMPIR, J.R. Simplot needs to prepare the Engineering Feasibility Study and Detection Monitoring Program by 10 October 2007 and deve:op a Corrective Action Plan to address cleanup of impacted soils and ground water in the area of the surface impoundments by 9 January 2008. Surface Release of Process Water from Auto Accident Upon completion of the remedial work to cleanup the affected soil from the unauthorized release and the new pipe diversion work from the tunnel sumps, J. R. Simplot was directed in our May 2006 letter to submit a Completion Report of all work activities associated with the release from the broken pipe no later than 14 August 2006 (45 days after the last activity date of 30 June 2006). As of this date, we have not received this report. Please make sure that this Completion Report is completed and submitted to this office. As requested in our letter, the Completion Report should provide, at a minimum, the following: