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STATE OF CALIFORNIA— ENVIRONMENTAL PROTON AGENCY • PETE WILSON, Governor <br /> CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD— <br /> CENTRAL VALLEY REGION <br /> 3443 ROUTIER ROAD, SUITE A gy. <br /> SACRAMENTO, CA 95827-3098 <br /> PHONE: (916) 255-3000 <br /> FAX: (916) 255-3015 <br /> 26 April 1993 <br /> ECEI <br /> APR2 81953 <br /> Mr. John R. Kiel ENVIRONMENTAL WEALTH <br /> Libbey-Owens-Ford PERMIT/SERVICES <br /> 811 Madigan Avenue <br /> P. 0. Box 799 <br /> Toledo, Ohio 43697-0799 <br /> MONITORING WELL WORK PLAN AND QUARTERLY MONITORING REPORT, LIBBEY-OWENS-FORD <br /> (LOF) COMPANY, SAN JOAQUIN COUNTY <br /> We are in receipt of Mr. Jon Weiss ' 9 April 1993 letter and the quarterly <br /> ground water monitoring report for the first quarter of 1993 for your Lathrop <br /> facility in San Joaquin County. <br /> The letter was submitted in response to our 15 March 1993 request for an <br /> additional monitoring well . The monitoring report transmits results of <br /> monitoring conducted in March 1993 and includes ground water flow directions <br /> and gradients. Our comments on these documents follow. <br /> 1. Figure 2 of the monitoring report shows three different ground water <br /> flow directions: almost directly north, northeast, and almost directly <br /> east. If the ground water flow direction fluctuates only from northeast <br /> to east, MWs 4 and 92-2 would provide adequate sampling points for the <br /> ground water emanating from the spill area. However, the ground water <br /> also flows approximately north of the spill area as evidenced in <br /> November 1992. When this occurs, MWs 4 and 92-2 do not provide coverage <br /> for sampling the ground water from the spill area. <br /> Item 2 of our 29 October 1992 letter requested the recent three years of <br /> monitoring data for the monitoring wells at Lathrop. LOF' s 11 December <br /> 1992 response stated that LOF would coordinate compilation of the data <br /> from the documents for a joint review by the Board and LOF, if the Board <br /> so desired. The letter also said that the 1985 data indicated a <br /> southerly ground water flow direction. We did not comment on the <br /> suggested joint review of the historical data. Nevertheless, LOF' s <br /> letter indicated that the ground water also has flowed to the south. <br /> The Bureau of Reclamation's ground water elevations for 1985 indicate a <br /> northeast regional ground water flow direction (towards the San Joaquin <br /> River) in the Lathrop area. Consequently, it is conceivable that the <br /> shallow ground water beneath your facility also flows in that direction. <br /> Unless LOF submits historical ground water data that show the predomi- <br /> nant ground water flow to be to the northeast or east, an additional <br /> ground water monitoring well shall be placed north of and as close to <br /> the spill area as possible. <br />