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STATE OF CALIFORNIA-Environmental Protectio ncy PETE WILSON, Governor <br /> CAOFDR1 A Kt:YIL)NACOPAItH UUMLII <br /> CENTRAL.VALLEY REGION 61V10 <br /> 3443 Routler Road,Suite A Sacramento, CA 95827-3098PHONE: (916)255-3000 <br /> FAX: (916)255.3015 <br /> 27 June 1994 <br /> JUL 6 1994 <br /> Mr. Jon Weiss ENVIRONMENTAL HEALTH <br /> Libbey-Owens-Ford PERMIT/SERVICES <br /> P. O. Box 128 <br /> Lathrop, CA 95330 <br /> COMMENTS ON THE SOIL AND GROUND WATER INVESTIGATION REPORT, <br /> TUNNEL CONSTRUCTION PROJECT, LIBBEY-OWENS-FORD (LOF) COMPANY, <br /> SAN JOAQUIN COUNTY <br /> I have reviewed Condor's May 1994 report entitled Soil and Ground Water Investigation <br /> and Soil Remediation for the tunnel construction project in the wareroom area at the <br /> Libby-Owens-Ford facility in Lathrop. My comments are presented below. <br /> 1. The Executive Summary is too long. It should be brief and concise. It should <br /> succinctly state the objectives of the investigation, whether these objectives have <br /> been met, any additional investigation needed to define the extent of soil and/or <br /> ground water contamination, and recommendations for remediation, if appropriate. <br /> 2. Each section need not have an introduction. <br /> 3. Figure 9 shows SB/HP-16 as "ND". Table 5 shows SB/HP-16 with free product. <br /> 4. Figure 13 shows extraction wells (EWs) 1 and 2 and monitoring well (MW) 93-2 <br /> within the limits of the excavation. The report states that MW 93-2 was damaged <br /> during the excavation and subsequently destroyed. The report does not explain how <br /> EWs 1 and 2 were spared when both wells are within the excavation area. <br /> 5. Figure 4 shows a northwest ground water flow direction with a gradient of 0.004 <br /> ft/ft. Based on this flow direction, there is no MW downgradient of the former <br /> locations of Hydros 1 and 2. Furthermore, the hydropunch sampling program <br /> indicated there was a limited free product and dissolved plume in the vicinity of <br /> Hydros 1 and 2. Therefore, to adequately monitor the presence and fate of hydrau- <br /> lic fluid in the ground, a MW should be placed in each of the former locations of <br /> Hydros 1 and 2 and downgradient of these locations. <br />