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Californ*Regional Water Quality COtrol Board : <br /> 1 r�%J Central Valley Region <br /> 111�0; Dr. Karl Longley, Chair f�``��":�' <br /> Linda Adams Arnold <br /> Secretary Sacramento Main Office Schwarzenegger <br /> Cal EPA 11020 Sun Center Drive 9200.Rancho Cordova.Califomia 95670-6114 Governor <br /> Phone(91 6)464-3291 • FAX(916)464-4645 <br /> http://v✓ww.Nvaterboards.ca.gov/centralvalley <br /> 1 February 2007 <br /> Mr. Don Wilden <br /> Pulte Homes <br /> 650 North Wilma Avenue, Suite 100 <br /> Ripon, CA 95366 <br /> CONDITIONAL CONCURRENCE WITH LIMITED SOIL AND GROUNDWATER SAMPLING <br /> AND ANALYSIS WORK PLAN, FORMER SUPREMA SPECIALTIES WEST, WASTEWATER <br /> POND NO. 7, MANTECA, SAN JOAQUIN COUNTY <br /> This letter provides Regional Board staff's comments on the subject work plan, which was <br /> prepared in response to a Regional Board staff letter dated 25 September 2006. The work <br /> plan proposes soil and groundwater sampling at two boring locations in order to characterize <br /> site conditions at Pond No. 7 and at a background location. A soil boring is proposed at the <br /> center of Pond No. 7, and the background boring is proposed about 50 northeast of Pond 7. <br /> Regional Board staff concurs with the subject work plan, conditioned upon the following <br /> requirements not specified therein: <br /> • Staff's consideration of potential nitrogen impacts to groundwater requires that both <br /> nitrate and ammonia data be collected in soil and groundwater. Pulte therefore needs <br /> to analyze soil and groundwater samples for ammonia along with the proposed nitrate <br /> analysis. Because staff consideration of nitrogen impacts doesn't require total kjeldahl <br /> nitrogen (TKN) data, Pulte may drop this analysis at its discretion. <br /> • Staff consideration of potential total dissolved solids (TDS) impacts to groundwater <br /> requires further speciation of TDS beyond that proposed in the subject work plan. Pulte <br /> therefore needs to additionally analyze soil and groundwater for sulfate and phosphate. <br /> In an email dated 5 December 2006, Joe Zilles of Kleinfelder stated that Pulte was <br /> agreeable to adding the sulfate analysis, but that he didn't see any basis for testing for <br /> phosphate since it has not historically been considered a constituent of concern. <br /> Regardless of this, staff considers phosphate a constituent of concern because it may <br /> have been discharged to Pond No. 7 (e.g., through the discharge of equipment cleaning <br /> agents), and because Kleinfelder's most recent site investigations included phosphate <br /> analyses (see site investigation reports dated 21 February 2006, 14 April 2006, and <br /> 18 May 2006). <br /> California Environmental Protection Agency <br /> �a Recycled Paper <br />