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f <br /> STATE OF CALIFORNIA-Environmental Protec .gency PETE WILSON Govemor <br /> CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD <br /> CENTRAL VALLEY REGION of <br /> 3443 Routier Road,Suite A <br /> Sacramento,CA 95827-3098 <br /> PHONE:(916)255-3000 <br /> FAX:(916)255-3015 9VS11yE1 <br /> 14 June 1995 J 0 N ;1 9 1995 <br /> ENVIIROPER�NMEN VCEN <br /> Mr. Nathan Esformes <br /> Triple E Produce <br /> Post Office Box 239 <br /> Tnicy, C^. 95378 <br /> WORK PLAN AND EVALUATION OF ALTERNATIVES FOR CONTAINMENT OF THE <br /> CHLOROFORM PLUME IN GROUND WATER, TRIPLE E PRODUCE, SAN JOAQUIN COUNTY <br /> I have reviewed the 31 May 1995 report entitled Work Plan and Evaluation of Alternatives for <br /> Containment of the Chloroform Plume in Ground Water submitted by Condor Earth Technologies, Inc. <br /> (Condor) for the Triple E Produce facility in Tracy. The work plan does not include a proposal for <br /> determining the extent of the chloroform plume as requested in my 18 April 1995 letter and does not <br /> adequately contain the plume. <br /> Extent of Chloroform Plume <br /> As stated in my 18 April 1995 letter, the Board is requiring Triple E to complete characterization of the <br /> ground water contamination. My earlier 3 June 1993 letter stated that if chloroform concentrations in <br /> MW7 increased further or did not decrease, it would be necessary to install additional monitoring <br /> well(s) downgradient of MW7 to determine the lateral extent of ground water contamination. Since it <br /> was first installed, the concentrations of chloroform in this well have increased from 8.7 ggll in October <br /> _ C, i 99 <br /> i�7(�2 to 22 µbi iii ir''1ar177✓. <br /> Capture Zone of Extraction System <br /> As shown in Figure 2 of the work plan, the proposed extraction from MW6 will not capture the entire <br /> chloroform plume. Although it is true that extracting from MW6 will result in decreasing chloroform <br /> concentrations in MW7, this will not be due to capturing the chloroform in MW7, but rather from the <br /> downgradient migration of the plume from somewhere between MW6 and MW7 to the north-northwest. <br /> This will result in further degradation of the ground water downgradient of MW6 and MW7. The <br /> alternatives considered for containment of the chloroform plume should include pumping from a well to <br /> contain the full extent of known contamination, i.e., extending at least to MW7. <br /> Disposal of Extracted Ground Water <br /> The proposal to dispose of extracted ground water to a spray field is unacceptable. Such disposal may <br /> result in contamination of soils in the spray field and possibly the underlying ground water. <br />