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California Tonal Water QualityControl_ or Central Valley Region Steven T.Butler,Chair Winston H.Hickox Cray Davis Secretan•jor Sacramento Main Office Governor Environmental Internet Address: http://www.swrcb.ca.gov/—rwgcb5 Protection 3443 Routier Road,Suite A,Sacramento,California 95827-3003 Phone(916)255-3000•FAX(916)255-3015 7 July 2000 w Paul Verma, �- City of Tracy ®• Public Works Department 520 Tracy Blvd. Tracy, CA 95376 CITY OF TRACY LAND TREATMENT FACILITY CLOSURE PLAN REVIEW,SAN JOAQUIN COUNTY, CALIFORNIA On 24 May 2000, the City of Tracy submitted to the Regional Board(Board) the"Closure Report- City of Tracy Class H Treatment Facility, W.D.O 94-216 Tracy, California". This report was drafted in response to the Board's 27 April 2000,Notice°of Violation. Upon review of the report, it is evident that additional work is required to accomplish the objectives presented in the Notice of Violation. The additional work includes compliance with Monitoring and Reporting Program (MRP)No. 94-216, and the completion of verification sampling. In the City of Tracy's closure report transmittal letter,it was requested that MRP No. 94-216 be revised to delete groundwater monitoring. "The City desires to exercise the modification to the MRP for groundwater monitoring as outlined in the RWQCB letter dated 19 April 1996." In the referenced letter, there is no provision for allowing the discharger to be dismissed from performing groundwater monitoring. The 19 April 1996 letter states: "Ground water monitoring wells will be installed and monitored per MRP No. 94-216. The City may request a revision to the MRP(modification of the monitoring parameters and sampling frequency) once the existing water quality concentrations are established". While the City may request a modification to the MRP, the Board staff may evaluate the modification if enough groundwater monitoring data has been collected to statistically establish water quality concentrations. Since the City has not yet initiated any of the mandated groundwater monitoring program,there is no data to support such a request. Upon review of the data presented in the closure report, it is evident that the verification sampling data reported for volatile organic constituents in the soil, is not valid. Consequently, the data described in the approved closure plan needs to be resubmitted. According to the U.S. EPA SW-846 Test Methods for Evaluating Solid Waste, Physical/Chemical Methods, the maximum storage time between sampling and analysis of the tubes should be 14 days. The rate of loss of sorbed volatile organic compounds from the tubes is both compound-specific and source-specific. A 14-day period is chosen for the holding time before analysis to provide a reasonably conservative guideline for quantitative analysis of the volatile organic compounds, which have been sampled. Soil samples collected from your site were submitted to California Environmental Protection Agency �a Recycled Paper