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Arnold Schwarzenegger <br />Governor <br />Alb California Retonal Water Quality Ientro! Board <br />Central Valley Region <br />Robert Schneider, Chair <br />Secretary for Sacramento Main Office <br />Environmental Internet Address: http://www.swrcb.ca.gov/rwqcb5 <br />Protection 11020 Sun Center Drive #200 Rancho Cordova, CA 95670-6114 <br />Phone (916) 464-3291 Fax (916) 464-4797 <br />15 September 2004 <br />Ms. Frances Schmiedt <br />20696 South Main Street <br />Manteca, CA 9533 <br />SEP 1 7 2004 <br />ENVIRONMEN1 HEALFH PERMIT/SERVICES <br />REVIEW OF WORK PLAN, SCHMIEDT SOIL SERVICE, 20696 SOUTH MAIN STREET, <br />MANTECA, SAN JOAQUIN COUNTY <br />Staff of the Central Valley Regional Water Quality Control Board (Regional Board) reviewed the <br />4 August 2004 Workplan Groundwater Monitoring and Soil Assessment/Delineation (Work Plan) <br />submitted by Kleinfelder on your behalf for the former Schmiedt Soil Service Incorporated property at <br />20696 South Main Street in Manteca (site). The Work Plan proposes to sample the three site <br />monitoring wells and report the results quarterly, collect soil samples to determine background soil <br />concentrations, and investigate the areas of MW-1 and MW-2, the former tank washout area, and the <br />former northern vehicle parking area to delineate the concentrations previous detected in soil. The <br />Department of Toxic Substances Control (DTSC) has also reviewed the Work Plan. <br />Regional Board and DTSC staff have the following comments on the Work Plan: <br />Section 3.2.1 proposes background samples based on the historic use of the area as an orchard. <br />This area may not be appropriate for background samples due to possible lead arsenate <br />applications. Additionally, the Work Plan proposes to collect soil samples at 1, 3, and 5 feet <br />below ground surface, but to only analyze the 5-foot sample. The rationale is needed for the <br />background sampling location and analysis of only the five-foot sample. <br />The Work Plan proposes samples to further investigate the areas around monitoring wells <br />MW-1 and MW-2, but none of the proposed samples is between the monitoring wells and the <br />edge of the site. Additional samples are needed to determine if any of the constituents of <br />concern have migrated off-site. <br />The Work Plan is not clear on the rationale for analyzing samples from the additional sampling <br />locations as alternating depths. Proposed sampling should address the extent of contamination <br />in each boring and not be limited to the analysis of a single sample from each location. <br />Otherwise, the extent of contamination will not be fully characterized. Given that most of these <br />releases are suspected of being surface releases, it seems more appropriate to analyze samples <br />from the surface to some depth. <br />California Environmental Protection Agency <br />Ci Recycled Paper <br />Terry Tamminen