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STATE OF CALIFORNIA-Environmental Protect;agency PETE WILSON,Governor <br /> CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD <br /> CENTRAL VALLEY REGION °' <br /> 3443 Routier Road,Suite A <br /> Sacramento,CA 95827-3098 `;1Lzp ; <br /> PHONE:(916)255-3000 v (f <br /> FAX:(916)255-3015 <br /> A PR 2 U 1995 <br /> 18 April 1995 ENVIRONMENTAL HEALTH <br /> PERMIT/SERVICES <br /> Mr. Nathan Esformes <br /> Triple E Produce <br /> Post Office Box 239 <br /> Tracy, CA 95378 <br /> GROUND WA TER REMEDIA TION A T TRIPLE E PROD UCE CORPORA TION, TRA CY, <br /> SAN JOAQUIN COUNTY <br /> I have reviewed the latest reports regarding the monitoring results and evaluation of the efforts to <br /> bioremediate the elevated levels of chloroform in ground water originating from the Triple E <br /> Produce Corporation in Tracy. These reports include the 6 February 1995 Progress and <br /> Quarterly Report submitted by PC Toxic, the 6 February 1995 Quarterly Groundwater <br /> Monitoring Report, Fourth Quarter 1994 submitted by AGRO Environmental Services, and the <br /> 9 February 1995 Assessment of Chloroform Genesis and Migration at the Triple E Produce <br /> Corporation Facility submitted by Condor Earth Technologies, Inc. (Condor). <br /> I disagree with the conclusions of the 6 February PC Toxic report that the chloroform <br /> concentrations in MW-7 have generally decreased. Chloroform concentrations in MW-7 have <br /> increased significantly since the well was first sampled in October 1992. The most significant <br /> increase in chloroform concentration in this well occurred between September and October 1994 <br /> when the concentrations increased from 10 µg/1 to 21 µg/1. Chloroform in MW-7 continued to <br /> increase to 28 µg/1 and 43 µg/1 in November and December 1994, respectively. <br /> The recent increase in chloroform in MW-7 occurred before the heavier than normal rains in early <br /> 1995, thus the increase is most likely due to liquid migration of the chloroform plume, rather than <br /> due to gas migration to the well in response to recent high intensity rainfall, as suggested in the <br /> 9 February 1995 Condor report. In that report Condor proposed to submit to the Board a ground <br /> water flow analysis and work plan for evaluation of gas phase transport within 30 days. We have <br /> not received this report. <br /> In my 6 July 1993 letter, I stated if chloroform concentrations increased in MW-7, we would <br /> require Triple E to install additional wells downgradient to determine the lateral extent of <br /> contamination. Due to the recent increases in chloroform in MW-7, Triple E is now required to <br /> complete characterization of the ground water contamination. <br /> In addition to defining the extent of ground water contamination, it is also necessary to prevent <br /> further migration of the plume. It is not necessary to wait for an evaluation of the effectiveness of <br /> the bioremediation before these activities occur since it is apparent that the plume is continuing to <br /> migrate beyond MW-7 in spite of the bioremediation being conducted at the source area. <br />