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*6 <br /> California R&ional Water Quality Wntrol Board "'' <br /> ` Central Valley Region <br /> Winston H.Hickox Steven T.Butler,Acting Chair Gray Davis <br /> Secretaryfor Sacramento Main Office Governor <br /> Environmental _ '11demet Address: httpJ/www.swrcb.ca.gov/- gcb5 <br /> Protection 3443 Routier Road,Suite A,Sarnsriento,California 95827-3003 <br /> Phone(916)255-3000•FAX(916)255-3015 <br /> 11 March 1999 <br /> Mr. Jon Weiss <br /> Libbey-Owens-Ford Co. <br /> P. O. Box 128 <br /> Lathrop, CA 95330 <br /> PRODUCT RECOVERY SYSTEM FOR THE DIESEL LINE SPILL, LIBBEY-OWENS-FORD <br /> COMPANY, SAN JOAQUIN COUNTY <br /> On 23 February 1999,you submitted a revised addendum to the 23 June 1997 Work Plan for the <br /> Standby Generator Diesel Supply Line Product Recovery System Installation and Monitoring Well <br /> Installation for the Libbey-Owens-Ford(LOF) facility in Lathrop. Our 9 March 1999 letter <br /> conditionally approved the monitoring well installation portion of this work plan. <br /> The original work plan proposed to remove existing floating diesel product through skimmers inside <br /> recovery wells in trenches. However, in December 1998, an attempt to install the recovery trenches <br /> failed because of unsafe conditions and the presence of utility lines. The 23 February 1999 addendum <br /> was supposed to evaluate other product recovery alternatives and select an alternative. Instead,the <br /> addendum proposed no product recovery. <br /> The diesel spill at your facility in Lathrop was discovered in July 1996. We approved a work plan <br /> addendum for product recovery and monitoring well installation in June 1998 and asked for a report on <br /> the product recovery trench system installation by 1 October 1998. Due to a funding oversight,LOF did <br /> not begin work on the product recovery system installation until December 1998, then encountered <br /> problems noted above,resulting in the product recovery system not being installed. During telephone <br /> discussions with staff on 15 December 1998,you stated that you would evaluate other product recovery <br /> alternatives such as using extraction wells. We concurred and specified that you should include this <br /> evaluation in the revised work plan due on 15 January 1999 which you requested be extended to <br /> 12 February. The 23 February work plan addendum did not include the necessary evaluation of <br /> alternatives and proposed no product recovery at all. <br /> We are very disappointed. After so many delays,you have submitted a revised product recovery work <br /> plan that is wholly inadequate. We are concerned that your proposal not to recover the separate phase <br /> product will result in further degradation of the groundwater. The water quality objectives (WQOs) for <br /> California Environmental Protection Agency <br /> ¢a Recycled Paper <br />