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r k 4 �, LC California 9,egional Water Quality Cor`-�ol Board %41b0 t Central Valley Region , e Robert Schneider, Chair 41b Linda S.Adams Arnold Secreraryjor Sacramento Main Office Schwarzenegger Environmental 1 1020 Sun Center Drive#200,Rancho Cordova,California 95670-6114 Governor Protection Phone(916)464-3291 •FAX(916)464-4645 http://www.waterboards.ca.gov/centralvalley nECE�JyE[o September 25, 2006 SEP 2 8 2006 SAN JOAQUIN COUNTY ENVIRONMENTAL HEALTH DEPT. Ella Foley-Gannon Sheppard, Mullin, Richter and Hampton, LLP Four Embarcadero Center, 17th Floor San Francisco, CA 94111-4106 FORMER SUPREMA CHEESE WASTEWATER POND, PUL TE HOME CORPORATION, MANTECA PROPERTY, SAN JOAQUIN COUNTY /5t a 53 5 , A t rp a/"f' This letter is in response to your letter to Pamela Creedon, Executive Officer of the Central Valley Regional Water Quality Control Board (Regional Water Board), dated September 7, 2006. The letter addresses, a residential development by your client, Pulte Horne Corporation, at the location of a wastewater pond used by the Suprema Cheese Company in Manteca. Duncan Austin of my staff informed you by phone on 19 September 2006 that we object to the filling in of the ponds without prior sampling to establish the threat to groundwater from the residual pond wastes and to determine the quality of the groundwater under the ponds. We appreciate your concern and we apologize for any misunderstanding that has apparently occurred regarding our reasons for requesting additional data related to the former Suprema Cheese Wastewater Pond. However, a review of the site history and data raises significant questions as to the remaining environmental threat posed by the wastewater pond and the degree to which groundwater has been impacted. The data that you provided so far does not support a no further action determination. Regional Water Board Cleanup Section staff met with Kleinfelder on April 26, 2006, regarding the project to build residential homes on the pond and surrounding areas, and discussed a report prepared by Kleinfelder dated February 21, 2006. That report described the abandonment of two groundwater-monitoring wells near the former wastewater pond and included the results of two shallow soil-sampling locations from the pond and one location 100 feet east of the pond'. The soil sample report provided limited data since very few samples were collected, none below 30 inches deep, and a limited analytic suite was used2. Sample results show that residual wastes are located in the former pond soils. The following table highlights some of these results: This second sample was designated as"background" but wastewater from the pond was applied to the fields in the vicinity of the pond. Therefore, this location may not be, in fact, a background location. '` For instance, the sampler noted "organic odors, much like manure, were noted within the pond samples",yet no analysis for ammonia, hydrogen sulfide, methane or other potential causes or hazards of the odor were performed. California Environmental Protection Agency Ca Recycled Paper