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STATE OF CALIFORNIA - Environmental ProtO Agency <br /> CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD PETE WILSON, Governor <br /> CENTRAL VALLEY REGION <br /> 3443 Routier Road, Suite A <br /> Sacramento, CA 95827-3099 ' <br /> PHONE: (a 16) 255.3000 <br /> FAX: (916) 255-3075 <br /> Mr. Matthew Fenske 18 November 1994 <br /> Holly Sugar Corporation <br /> P.O. Box 60 <br /> Tracy, CA 95378 <br /> SURFACE SPILL ASSESSMENT, HOLLY SUGAR FACILITY, TRACY, SAN JOAQUIN COUNTY <br /> I have reviewed the 14 November 1994 Phase II Surface Spill Assessment report submitted by <br /> Harding Lawson Associates on behalf of Holly Sugar. A significant number of soil samples and two <br /> hydropunch ground water samples have been taken and analyzed from the two spill areas at the site. <br /> At the former corn refinery area, surface soils revealed up to 160,000 mg/kg of total recoverable <br /> petroleum hydrocarbons to <br /> ground surface (bgs) nearr the using EPA Method 418.1. Approximately 12 feet below the <br /> the top of the ground water table, soils contain up to 4,100 mg/kg of <br /> TRPH. At the existing aboveground storage tank area, surface soils showed up to 7,300 mg/kg of <br /> TRPH, and soils near the top of the water table (approximately 10 feet bgs) showed up to 3,900 <br /> mg/kg of TRPH. The full lateral extent of soil contamination at both areas is still undefined. <br /> Both of the hydropunch ground water samples showed nondetectable concentrations of TRPH. <br /> Along with the fact that the tanks at the site were historically used for storing diesel and fuel oils, <br /> the hydropunch results suggest that these relatively heavy (and characteristically immobile) <br /> petroleum species which contaminate the soils are not currently a source of ground water <br /> contamination. However, to avoid excavation and disposal or remediation of the soils, leachability <br /> tests on the soils must be conducted. The waste extraction test (WET) is an acceptable method to <br /> obtain a conservative estimate of the threat these soils may pose to the ground water. <br /> The November report failed to include recommendations for further investigation and/or remediation <br /> as we requested in our 24 August 1994 letter. By 23 December 1994, please provide a work plan <br /> and time schedule to either conduct soil leachability tests, or excavate or remediate the contaminated <br /> soils. In addition, we are aware that there are a number of ground water monitoring wells already <br /> installed at the Holly Sugar facility. By 23 December 1994, please submit a site map which shows <br /> these wells in relation to the spill areas, and any monitoring data which can be used to decipher the <br /> ground water flow direction and gradient. <br /> If you have any questions, you may call me at (916) 255-3077. <br /> w <br /> jcw <br /> L M. WEISS <br /> Engineering Geologist <br /> Jw.,jmw/lsb <br /> cc: San Joaquin County Public Health Services, Stockton <br /> Mr. Chris Beegan, Harding Lawson Associates, Sacramento <br />