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California0gional Water Quality Con4jl Board
<br /> Central Valley Region
<br /> Karl E. Longley,ScD,P.E.,Chair ,..••-f
<br /> Linda S. Adams Arnold
<br /> Secremryfor Sacramento Main Office
<br /> 11020 Sun Center Drive#200,Rancho Cordova,California 9567061 I4 Schwarzenegger
<br /> F.n oles emal Governor
<br /> Prolecrion Phone(916)464-3291 •FAX(916)464-4645
<br /> htip:lh%ww.waterboards.ca.gov/centralval ley
<br /> 5 December 2007 nIECI VE
<br /> D
<br /> Ms. Eugenia Valdez DEC 0 6 2007
<br /> J&L Market ENVIRONMENT HEALTH
<br /> 8125 EI Dorado Street PERMIT/SERVICES
<br /> French Camp, CA 95231
<br /> DOCUMENT REVIEWS, J&L MARKET, 8125 S. EL DORADO ST., FRENCH CAMP,
<br /> SAN JOAQUIN COUNTY
<br /> I reviewed seven Monitoring Reports (1st Quarter 2006 through 3rd Quarter 2007) and a
<br /> Subsurface Investigation Workplan (Workplan) submitted electronically to GeoTracker and in
<br /> paper copy from 20 August 2007 through 19 November 2007 by your consultant ATC
<br /> Associates, Inc. (ATC). Prior to receiving the documents, I contacted ATC by phone on
<br /> 9 August 2007, to discuss the submittal of late monitoring reports, and the Workplan required
<br /> by my 1 December 2005 letter. I received assurances from Todd Hafner of ATC that all
<br /> monitoring had been completed, but that due to an oversight, the reports and workplan were
<br /> not submitted to State Board's GeoTracker database or to the Regional Board. Subsequent to
<br /> our conversation, the documents began to appear as individual submittals to Geotracker and
<br /> as written copies to this office over the span of three months.
<br /> The Report for the Second Quarter 2007 (2Q2007), received electronically from Geotracker on
<br /> 15 October 2007 and subsequently as a paper copy, concludes that there is evidence of a
<br /> new release at your site. The 2Q2007 states the laboratory identified diesel fuel in
<br /> groundwater sampled from monitoring well JLM-13 as "not weathered" (fresh), with results for
<br /> Total Petroleum Hydrocarbons as diesel (TPHd; 6,100 micrograms per Liter, or ug/L),
<br /> Total Petroleum Hydrocarbons as gasoline (TPHg, 390 ug/L), benzene (B; 1,400 ug/L),
<br /> toluene (T, 85 ug/L), ethylbenzene (E; 1,100 ug/L), and xylenes (X; 860 ug/L). Table 2 (pages
<br /> 2 & 3 of 4, enclosed) show that TPHd and BTEX have increased in JLM-13 from first quarter
<br /> of 2006 to the second quarter of 2007, however the 2Q2007 also stated the TPHd reported in
<br /> fourth quarter of.2006 was "weathered" (old) diesel, and not indicative of a new release.
<br /> In contrast to the 2Q2007, the Monitoring Report Third Quarter 2007 (3Q2007) does not
<br /> reiterate the conclusion of a new TPHd release, but does recommend reducing sampling
<br /> frequency for consistently non-detect wells JLM-18 and JLM-19. The 3Q2007 data show that,
<br /> for JLM-13, the following concentrations showed a decrease from the previous quarter: TPHd,
<br /> 3,700 ug/L; B, 220 ug/L; T, 2.8 ug/L; E, 220 ug/L; and X, 32.6 ug/L; while TPHg increased to
<br /> 2,000 ug/L. The 3Q2007 states a split (duplicate) sample for JLM-13 was taken, sent to a
<br /> second lab (Exochem of Rocklin), and analyzed only for TPHd. The 3Q2007 concludes that
<br /> the TPHd split sample result (3,260 ug/L) "...is consistent with..."the primary sample result
<br /> (3,700 ug/L) from the primary laboratory. SPL of Houston TX. The 3Q2007 data also show
<br /> California Environmental Protection Agency
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