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0 <br /> .STATE OF C-ALJFJRNIA — ENVIRONMENTAL PROTECTION AGENCY PETE WILSON. Gove,,c' <br /> CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD— <br /> - - � <br /> CENTRAL VALLEY REGION <br /> 3443 ROUTIER ROAD. SUITE-A <br /> SACRAMENTO. CA 95827-3098 ice / <br /> PHONE: (916) 255-3000 <br /> FAX: (916) 255-3015 <br /> n <br /> � . tz <br /> 29 October 1992 �f ' <br /> NOV 4 1992 <br /> ENVIRONMENTAL HEALTH <br /> PERMIT/SERVICES <br /> Mr. John R. Kiel <br /> Libbey-Owens-Ford Company <br /> 811 Madigan Avenue <br /> P. 0. Box 799 <br /> Toledo, Ohio 43697-0799 <br /> SITE ASSESSMENT REPORT, LIBBEY-OWENS-FORD COMPANY, SAN JOAQUIN COUNTY <br /> We have reviewed your 7 October 1992 letter and the accompanying investigation <br /> report assessing the impact to soil and ground water of the fuel oil release at <br /> LOF' s facility in Lathrop. Our comments below pertain to both your letter and the <br /> report since they present essentially the same results and proposals. <br /> 1. The letter states that monitoring well (MW) 4, which has a relative elevation of <br /> 49.88 feet, was used as a benchmark when MW-92-1 and MW-92-2 were surveyed. Was <br /> MW4 resurveyed to confirm if its elevation is still 49.88 feet? <br /> 2. The letter states that information regarding ground water elevations at the site <br /> has been developed over many years and current ground water elevation data are <br /> provided in the report. How long ago were existing data collected? Were the <br /> gradients at that time consistent with the gradient from the recent data? We <br /> request that ground water data and contours from the latest three years of <br /> historical data be submitted to the Board. <br /> 3. The letter states that the borrow soil sampling protocols were sufficient and <br /> further analysis was not necessary. As stated in our 27 August 1992 letter, <br /> compositing of soil samples is inappropriate in characterizing the borrow area <br /> because if contamination is detected it would be difficult to identify the exact <br /> location of the source. Also, compositing results in dilution of any pollutant, <br /> may cause volatilization of pollutants, and would not characterize the borrow <br /> area since the results would be characteristic of the composite. Furthermore, <br /> the two composite samples taken on 15 May 1992 are inadequate to characterize <br /> 1,500 cubic yards of materials. The two samples also were analyzed for only <br /> three metals with no explanation of why this was done. <br /> Our letter of 27 August also stated that one discrete sample must be taken per <br /> 50 cubic yards of material and tested for total extractable petroleum hydrocar- <br /> bons (TEPH) , benzene, toluene, ethylbenzene, and xylene, (BETX) and metals. <br /> Metals testing must include any metals that might be present. <br />