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California Regional Water Quality Control Board <br /> Central Valley Region <br /> Robert Schneider,Chair <br /> Winston H.Hickox Gray Davis <br /> Secretary for Sacramento Main Office Governor <br /> Environmental Internet Address: http://www.swrcb.ca.gov/rwgcb5 <br /> Protection 3443 Routier Road,Suite A,Sacramento,California 95827-3003 <br /> Phone(916)255-3000•FAX(916)255-3015 <br /> 6 September 2001 <br /> Mr. Tom Guido <br /> Triple E Produce <br /> P.O. Box 239 <br /> Tracy, CA 95378 <br /> REVIEW OF RESPONSE TO COMMENTS, TRIPLE E PRODUCE, TRACY, SAN <br /> JOAQUIN COUNTY <br /> We have reviewed the 30 August 2001 Response to Comments (Response) submitted by Condor <br /> Earth Technologies, Inc. (Condor) for Triple E Produce (Triple E) at 8690 West Linne Road, <br /> Tracy(site). The Response replies to the six comments in our 7 August letter review of the <br /> 20 July Groundwater Monitoring Report Second Quarter 2001. The Response provides Table 3 <br /> and Figure 9 with the information that was previously omitted, rebuts three of the comments, and <br /> informs Board staff that monitoring wells will remain in place during the upcoming scheduled <br /> sampling event because grading activities have not started at the new housing development area. <br /> We have the following comments on the Response: <br /> 1. The Response concurs that chloroform concentrations in MW-1 and XW-1 have a slightly <br /> positive trend since shutdown of the groundwater extraction system but states that the <br /> standard deviations of the five samples collected since shutdown are higher than the <br /> projected trend increase. Condor references ASTM Proposed Standard Practice for <br /> Simplified Identification of Trends in Environmental Monitored Media as a non- <br /> parametric test that when applied shows"no significance attached to the apparent trends <br /> presented in Figure 9 at this time, and the trends are essentially flat." Board staff does not <br /> agree with the use of the proposed ASTM standard referenced because it is not yet <br /> approved and a minimum of six data points (five comparisons) are required to use the <br /> test. Therefore, Board staff still does not agree with the original comment,"Chloroform <br /> plume continues to diminish along predicted trends" and requires additional quarterly <br /> monitoring. <br /> 2. The Response clarifies that the WDR Order No. 96-118 is for discharge from the <br /> groundwater extraction system and WDR Order No. 99-123 is for discharge from the <br /> wash water treatment plant. Board staff will recommend rescission of WDR Order No. <br /> 96-118 along with a new Monitoring and Reporting Program for continued site <br /> monitoring. <br /> California Environmental Protection Agency <br /> 0 Recycled Paper <br /> The energy challenge facing California is real. Every Californian needs to take immediate action to reduce energy consumption. For a list of <br /> simple ways you can reduce demand and cut your energy costs,see our Web-site at http://www.swrcb.ca.gov/rwgcb5 <br />