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fillwmbag Libbey • • <br /> Owens <br /> NO Ford <br /> A member of the Pilkington Group <br /> Libbey-Owens-Ford Co. <br /> August 23 , 1994 500 East Louise <br /> P.O. Box 128 <br /> Lathrop,California 95330 <br /> Tel.209858-5151 <br /> TWX 510-762-6630 <br /> Mr. Philip Isorena FAX 209.858-2024 <br /> California Regional Water Quality <br /> Control Board: Central Valley <br /> 3443 Routier Rd. , Suite A <br /> Sacramento, CA 95827 <br /> Re : Monitoring & Reporting Program: Wareroom Area <br /> Dear Mr. Isorena: <br /> The Libbey-Owens-Ford Co. (LOF) has received and reviewed the <br /> proposed Monitoring and Reporting Program (MRP) for the wareroom <br /> area where the hydraulic sumps formerly operated. As a component <br /> of the Soil and Groundwater Investigation and Soil Remediation <br /> Report submitted to the Regional Water Quality Control Board <br /> (RWQCB) on May 24, 1994, LOF proposed a groundwater monitoring <br /> program. The objective of initiating a groundwater monitoring <br /> program was to permit a more detailed characterization of the <br /> wareroom area site. <br /> The proposed groundwater monitoring program does not include <br /> groundwater remediation activities . LOF believes it would be <br /> premature to begin planning groundwater remediation activities <br /> prior to characterizing the groundwater at the wareroom area site . <br /> Therefore, LOF proposes to use the two extraction wells for <br /> groundwater monitoring only at this time . <br /> The RWQCB proposed MRP mentions remediation several times . An <br /> example is on page two, first paragraph: "Prior to startup of a <br /> ground water treatment system, the Discharger shall supply Board <br /> staff with a ground water monitoring program that will demonstrate <br /> the effectiveness of the ground water treatment system. " LOF <br /> believes that the MRP should address only groundwater monitoring at <br /> this time. Therefore, LOF requests that all mention of activities <br /> associated with groundwater remediation be removed from the <br /> proposed MRP . <br /> Additionally, LOF proposes new text under the title REPORTING (page <br /> 1 of MRP) that includes the removal of the first sentence . The <br /> proposed text is as follows : "Six consecutive quarterly reports <br /> shall be submitted to the Board by the 30th day of the month <br /> following the end of each calendar quarter. Monitoring will <br /> commence the calendar quarter following adoption of the MRP . <br /> Within 60 days upon completion of the groundwater monitoring <br /> program, LOF will submit to Board staff a proposal outlining <br /> further activities to be taken based upon the results of the <br /> monitoring program" . <br /> r <br /> PILKINGTON <br />