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1500 Newell Avenue,Suite 800 <br /> Walnut Creek,California 94596•USA <br /> GEOSYNTEC CONSULTANTS <br /> Tel. (925)943-3034•Fax(925)943-2366 <br /> 14 April 2003 <br /> E c]YED <br /> Ms. Amy Terrell 4PR 16 20(13 <br /> California Regional Water Quality Control Board <_,Vfv)ENT HEALTH <br /> Central Valley Region - MIT/SERVICES <br /> 3443 Routier Road, Suite A <br /> Sacramento, California 95827 <br /> Subject: Comments on Draft Monitoring and Reporting Plan and <br /> Schedule for Soil Cleanup <br /> Western Farm Service, Inc. <br /> Vernalis, California <br /> Dear Ms. Terrell: <br /> This letter provides comments on the draft Monitoring and Reporting Plan (MRP) <br /> and a schedule for soil investigation activities, as requested by the California Regional <br /> Water Quality Control Board, Central Valley Region (RWQCB). GeoSyntec <br /> Consultants, Inc. (GeoSyntec) prepared this letter on behalf of Western Farm Service, <br /> Inc. (WFS), in response to the RWQCB's 5 March 2003 transmittal of the draft MRP <br /> for the WFS facility in Vernalis, California. <br /> COMMENTS ON MRP <br /> The RWQCB issued a draft MRP for the WFS Vernalis site in response to requests <br /> from GeoSyntec for substituting certain analytical methods for total oxidizable nitrogen <br /> and carbamate and urea pesticides, and reducing the frequency of the groundwater <br /> monitoring program from quarterly to semi-annually. The RWQCB had verbally <br /> approved these requests, and issued the draft MRP to reflect the changes. <br /> WFS and GeoSyntec comments on the draft MRP are as follows: <br /> ■ In the MRP title/header, remove "AGRIIJM INCORPORATED AND" and <br /> remove the second sentence of paragraph one. WFS is a legal entity registered <br /> as a corporation in the State of Delaware, and is the"discharger." <br /> P:\PRJ2003REM\WFS\VER\Terrell RTC 4 2003.doc <br />