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California U-gional Water Quality Cont- it Board 0111"fu- <br /> Linda <br /> Central Valley Region <br /> Karl E.Longley,ScD,P ai S.Adams _ _ i Arnold <br /> 1 1020 Sun Center Drive 4200,Rancho Cord 'va, g't" � tl( <br /> Secretaryfor Phone(916)464-3291 •FAX(916)464-4645 �' Schwarzenegger <br /> Environmental http://),vww.waterboards.ca.gov/centffLya�lei Governor <br /> Protection —4 t s zoC9 <br /> ENVfRONMc-NT 11 f, <br /> 17 September 2009 f�€f�NTlfi� f WCE-5 <br /> Mr. Tim Van,-Qomelen <br /> Manager, Environmental Health, Safety, and Security <br /> J. R. Simplot Company <br /> 16777 Howland Road <br /> Lathrop, CA 95333-0198 <br /> FEASIBILITY STUDY FOR CORRECTIVE ACTION— J.R. SIMPLOT COMPANY, <br /> 16777 HOWLAND ROAD, LATHROP, SAN JOAQUIN COUNTY <br /> The California Regional Water Quality Control Board, Central Valley Region (Central Valley <br /> Water Board) staff have received the Feasibility Study for Corrective Action (FS), dated <br /> 24 July 2009, submitted on behalf of J. R. Simplot by AMEC Geomatrix, Inc. (Geomatrix). In <br /> the FS, Geomatrix describes the objectives, rationale, and evaluation of alternatives for the <br /> remediation of nitrate, sulfate, and ammonium in soil and groundwater at the J.R. Simplot <br /> facility at 16777 Howland Road, Lathrop. <br /> The objective of corrective action, according to Geomatrix, is "to remediate groundwater and <br /> soils such that current and designated beneficial uses of groundwater are restored." The FS <br /> presents evaluations of the following remedial technologies for groundwater: <br /> • No action. <br /> • Monitored natural attenuation. <br /> • Extraction and treatment. <br /> • Extraction and reuse. <br /> For soils, the following technologies are evaluated: <br /> • No action. <br /> • Soil capping <br /> Excavation and agricultural reuse. <br /> Geomatrix proposes extraction and reuse of groundwater and the no-action alternative for <br /> soils as the selected technologies. A conceptual corrective action plan is incorporated in the <br /> FS outlining the steps to complete a pilot test of the groundwater extraction and reuse <br /> alternative. <br /> I have reviewe-d-ttre FS and have the following comments. <br /> 1. Geomatrix states that "none of the remedial alternatives for soil are likely to be effective <br /> either in achieving corrective action goals or in cost." They further state that "groundwater <br /> extraction and treatment would not achieve corrective action objectives but would serve <br /> as a source control remedial measure." As you may be aware, additional remedial <br /> California Environmental Protection Agency <br /> ci Recycled Paper <br />