SITE INFORMATION AND CORRESPONDENCE_FILE 1

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Ms. Donna Murphy - 2 - 11 April 2000 Notice of Noncompliance J.R. Simplot Company Sampling Location Results (µg/L) PW-1 (monitoring well) ND LP-3 (monitoring well) ND LP-1 (monitoring well) ND Stormwater Pond ND North Pond 1500 West Pond 560 South Pond 2300 2. Numbered issues between 1 and 8 should be revised to meet the minimum standards required by Order No. 97-229. Standard Provisions and Reporting Requirements (SPRR), Provisions for Monitoring, Section 1 requires the Discharger to maintain a written Sampling and Analysis Plan (SAP) sufficient to assure compliance with the terms of Order No. 97-229. Section 4 states that all sample analyses shall be conducted at a laboratory accredited for such analyses by the State Department of Health Services. The Quality Assurance-Quality Control Program (QA/QCP) must conform to EPA guidelines (e.g., "Laboratory Documentation Requirements for Data Validation," January 1990, USEPA Region 9) or to procedures approved by the Board. Please submit a complete and adequate SAP and QA/QCP by 1 July 2000 in conformance with Order No. 97-229. 3. Item number 9 of your letter discusses the fact that a pump is lodged at the bottom of well LP- 2. This pump must be removed and the well reconditioned to function as a viable sampling point of compliance. The other option is to officially abandon LP-2 and install a new well that would function in the same capacity as the existing well. In either case, the monitoring well must meet the minimum requirements set forth in Title 27, California Code of Regulations (Title 27), §20415. Included in this section is the requirement that all monitoring systems be designed and certified by a registered geologist or a registered civil engineer. The SPRR, Provisions for Monitoring, Section 3 also states that the Discharger must construct or abandon all monitoring wells to meet or exceed the State Department of Water Resources Bulletin 74- 81 and subsequent revisions, and must comply with the reporting provisions for wells required by Water Code Sections 13750 through 13755. Please provide a work plan by 1 June 2000 which describes how LP-2 will be reconditioned or abandoned and replaced with a new well as a viable point of compliance. Grouud;vater Quality According to Order No. 97-229, Finding No. 22, one downgradient monitor well (LP-1) has exhibited concentrations of TDS as high as 12,000 mg/l. Background monitor wells indicate that groundwater in the area contains concentrations of TDS ranging from 800 to 1000 mg/l. Therefore, data shows that the downgradient well has been impacted from the waste management units.