Laserfiche WebLink
California Regional Water Quality Control Board <br /> Central Valley Region <br /> Steven T. Butler, Chair <br /> Winston H. Hickox Gray Davis <br /> Secretalyfor Sacramento blain Office Governor <br /> Environmental Internet Address: http:/Avww.swreb.ca.gov/—rwgcb5 <br /> Prosection 3443 Routier Road,Suite A,Sacramento,California 95327-3003 <br /> Phone(916)255-3000•FAx(916)255-3015 <br /> C� <br /> 2 November 2000 �- <br /> t <br /> Ms. Donna Murphy <br /> J.R. Simplot Company C' <br /> 16777 Howland Road <br /> P.O. Box 198 <br /> Lathrop, CA 95330-0198 <br /> WORK PLAN FOR RECONDITIONING MONITORING WELL LP-2, J.R. SIMPLOT <br /> COMPANY, LATHROP PLANT, SAN JOAQUIN COUNTY, Case No. 3876 <br /> We have reviewed the Work Plan for Reconditioning Monitoring Well LP-2 (Work Plan), dated <br /> 27 October 2000, as prepared by Geomatrix Consultants, Inc. Submittal of this document is in <br /> compliance with one of the requirements stated in the Board's Notice of Violation letter to J.R. <br /> Simplot Company, dated 1 September 2000. <br /> We concur with the scope of work in the Work Plan, which proposes the reconditioning of Well <br /> LP-2. A pump is to be removed and the well bore video surveyed to verify the condition of the <br /> well as a viable monitoring point of compliance. If the video survey shows significant damage to <br /> the casing or if the pump cannot be removed, a work plan will be prepared for destruction of well <br /> LP-2 and installation of a replacement well. In either case, J.R. Simplot should ensure that they <br /> comply with the Standards and Provisions Monitoring Requirements which state, "The <br /> discharger shall construct or abandon all monitoring wells to meet or exceed the standards <br /> stated in the State Department of Water Resources Bulletin 74-81 and subsequent revisions, and <br /> shall comply with the reporting provisions for wells required by Water Code Sections 13750 <br /> through 13755. " <br /> According to the Work Plan, the graph on Figure 3 shows that the TDS results from LP-2 track <br /> closely with the other monitoring wells in terms of seasonal variations and occasional extremes. <br /> This may be true, but we contend that the water in LP-2 does not represent fresh formation <br /> aquifer water representing each sampling event. Standard sampling protocol requires that at least <br /> three well volumes of water be purged from the well in order to ensure that fresh formation water <br /> is sampled for analysis. Since the pump is stuck above the screened interval, purging 3 wells <br /> volumes prior to sampling could not have occurred. Therefore, data representing TDS values <br /> since the pump was stuck in the well above the screened interval should not be considered <br /> representative of actual formation water at the time of sampling. In this regard, J.R. Simplot <br /> should ensure that the Sampling and Analysis Plan (SAP) and Quality Assurance and Quality <br /> Control Plan (QA/QCP), required to be submitted by 1 January 2001, include a comprehensive <br /> sampling protocol according to industry standards. <br /> California Environmental Protection Agency <br /> CC?Recycled Paper <br />