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TEL ;-Wo . Ha•r 9 16 012 P . 01 Post-11 "brand lax transmVn,,MC, a pages ► To �� rJ Co 83 WEST MARCH U � �-�OeptSUITE 12 STOCKTON.CA 952PHONE'(209)476-1r _ .t�,g.ERS p pt�AS�CONSJITMrtS February 24, 1993 Ms. Polly Lowry )Pit a California Regional Water Quality Control Board 3443 Routier Road, Suite A MAR 17 1993 Sacramento, CA 958.17-3098 W.U. No. 03374-()()4-f ?1 ENVIRONMENTAL HEALTH RE: Schedule Advisory and Project Status PERMITISERVICES Triple E Produce Groundwater Froject, Tracy, California Dear Ms. Lowry, On behalf of Triple E Produce, this letter is to advise you of efforts being inade to address the actions requested by your January 26, 1993 letter to Mr, Nathan Eyformes. We are concerned that a system to capture all of the groundwater contamination may be cost prohibitive based o� Triple E's financial resources and may not be necessary to protect domestic uses of underlyin groundwater. Nonetheless, we will investigate such a system. As you know, Triple E's Tracy, California. plant is closed this time of year and the company s operations are at several locations in South Florida. Furthermore, Mr. Esfurmes is currently out of the country until mid-March. These circumstances have not allowed sufficient discussions between Triple E's management and the project's technical consultants to adequately respond to your letter. These discussions are critical as the program is now at the point where significant commitments of time and finances are evident. This is particularly true at this time as your recent letter indicated the Board has reservations about the proposed source control approach to remediation. Also, this critical paint in the program has come at a difficult time for Triple F which is suffering the adverse fillarrcial ei ,,-CtS of the �'G1'ielli. JUA:CSa,1011. 1110,11", ,illy luCC:-}+�,r or conunitment must be thoroughly studied, both in terms of immediate actions and long-tern: implications. Of special concern is the treatment plant issue. As proposed in the November 1R Remedial Plan, the existing treatment plant would have been used for the groundwater p! as long as the program's extraction rate does not exceed the plant's limited (current de capacity. Therefore, if there is a possibility that higher processing rates will be required service either a larger source control or an expanded containment type of program, it is doubtful that the financial resources required to place the existing plant in groundwater remedial service -n can be justified. Prior to your January letter, this was not a significant issue. Other treatn;ent �M `c plant alternatives, while initially more expensive, inay be a better approach for the long tent crt but will require longer lead times to become operational. JS-•LON'Ky V.'Y - CSl .