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Mr. Joe Herrud, Leprino Ids - 2 - 4 March 2014 <br /> Leprino Facility, 2401 MacArther Drive, Tracy <br /> have declined and/or been consistently below laboratory detection limits; therefore the <br /> natural attenuation exceeds the leaching potential. <br /> • Leprino has spent over$1,250,000 characterizing and remediating the Site. Leprino <br /> estimates the cost to remove the remaining impacted soil would cost millions of dollars <br /> because the release is beneath the operational area of the active plant. <br /> • Since 1996 the gradient control and treatment system has removed 2,769 gallons of <br /> product and treated 63.7 million gallons of groundwater. <br /> • Leprino calculated the time to reach WQOs in Site groundwater. The plume is stable (as <br /> defined in the State Water Board's Low-Threat Underground Storage Tank Case Closure <br /> Policy) and the downgradient monitoring wells are below the WQOs. Leprino evaluated <br /> the regression data from these downgradient wells and states that the concentration in the <br /> source area wells will reach WQOs in approximately 13 years. <br /> • The Letter states the total dissolved solid (TDS) concentration in the shallow groundwater <br /> wells in the area exceeds the Environmental Protection Agency (EPA) secondary <br /> maximum contaminant level (MCL) and is therefore unsuitable for drinking. <br /> Our comments are: <br /> 1. Central Valley Water Board staff concurs with the request for an extension to the <br /> groundwater monitoring and sampling requirement in order to allow time for the <br /> preparation of a work plan for groundwater sampling. By 23 May 2014, Leprino should <br /> submit a report evaluating Site groundwater data and a work plan for the wells proposed <br /> for sampling. <br /> 2. Central Valley Water Board staff does not concur with the Addendum request for Site <br /> closure or the estimate to reach WQOs. Leprino needs to collect an adequate number of <br /> groundwater samples from Site monitoring wells to evaluate the current concentrations to <br /> assess when Site groundwater will reach WQOs. <br /> 3. Central Valley Water Board staff understand Leprino has been in communication with <br /> State Water Board staff. Central Valley Water Board staff request that Leprino copy Board <br /> staff on any further written communication with State Water Board staff. <br /> In summary, by 23 May 2014 Leprino needs to submit a report evaluating current Site <br /> groundwater data and a work plan for sampling. In addition, Leprino needs to continue to <br /> communicate with Board staff. If you have any questions regarding this letter, you may contact <br /> me by phone at (916) 464-4819 or by email at ksheltonaa.waterboards.ca.gov. <br /> KRISTI SHELTON, P.E. J Pa4tf <br /> Water Resources Control Engineer Ch' , Storage Tanknt Unit 1 <br /> Storage Tank Enforcement Unit 1 <br /> cc: Ms. Lori Duncan, San Joaquin County Environmental Health Services, Stockton <br /> Mr. Reed Azevedo, Leprino Foods Company, Tracy <br /> Mr. Brendan Shine, Golden, Colorado <br />