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W, 0 0 STATE OF CALIFORNIA GEORGE DEUKMEJIAN, Governor CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD - CENTRAL VALLEY REGION Z�_3201 S STREETf SACRAMENTO,CALIFORNIA 95816-7090 PHONE: (916)445-0270 25 June 1984 �u= 490 fJ n 4 Mr. A. J. Diepenbrock A Oil 515 Hope Street, Suite 202 South Pasadena, CA 91030 HOLT CLASS III DRILLING MUD DISPOSAL SITE, SAN JOAQUIN COUNTY In regards to your 4 June 1984 letter, we have the following comments: 1. Using "the nearest drainage canal" to collect background samples for comparison to monitoring well data is not appropriate. The drainage canals on Roberts Island are used to remove shallow ground water in draining the island. Since the shallow ground water has been contam- inated by the disposal site it makes no sense to use the drainage canal waters for background comparisons® 2. We will not conduct a three month, bi-weekly monitoring program for the existing monitoring wellsin conjunction with Nelson and Zalco Labora- tories. The analytical results submitted to our office by Arcady, and performed by Nelson Laboratories, have consistently shown contam- ination of both the drilling muds and the shallow ground water for more than a year. If Arcady or Zalco Laboratories has specific technical information to invalidate these results it should be submitted immediately® 3. Our 11 June 1984 letter clearly identifies our approach in assessing contamination at the Holt site. Please reference this letter and use it as a guide in investigating contamination on-site. As shown by the above comments, your 4 June response to our 1 May 1984 request for a sampling plan is inadequate. We again request that you submit a sampling plan with an appropriate time schedule, to define the extent of soil and ground water contamination resulting from the site. This plan should be received by our office no later than 9 July 1984. Failure to submit a plan by this date may result in further enforcement actions by the Board.