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STATE OF CALIFORNIA • PETE WILSON Governor CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD— CENTRAL VALLEY REGION , SAAR R ROAD, SUITE A SACRAMENTO, CA 95827-3098 N !81 a tr'•i ff y6,,la PHONE ( 6) 3 0 AUG 2 2 FAX: (916)) 5686 361-5686 UN''VIF�NMT'JTA'._ HGAL111-1 NE.1�Igj i /V(_f(YiIiLJ 20 August 1991 Ms. Cheryl R. Mitchell Natural dtui'ai Food Products � Post Office Box 1219 Lathrop, CA 95330 SITE REMEDIATION, CALIFORNIA NATURAL FOOD PRODUCT, LATHROP, SAN JOAQUIN COUNTY Thank you for your August 1, 1991 letter submitting the Problem Assessment Report prepared by Augeas Corporation. A draft copy of the Remediation Workplan was not included in your submittal . A cursory review of your Assessment Report indicates that soils have been contaminated with Total Petroleum Hydrocarbons (TPHs) up to 2600 mg/kg, and ground water has levels of up to 1400 µg/l of benzene, well above the State Action level of 1.0 µg/1 . You have polluted and threaten to pollute the waters of the state and will have to clean up your contamination in accordance with Section 13304 of the Water Code. We do concur with the concept to use soil venting/vapor extraction to start remediating the soil contamination. However, we do not concur with the postponement of any groundwater investigation, considering the localized, high concentrations of benzene. You, therefore, should proceed during Phase 1 with further definition of the vertical and horizontal extent of the contaminant plume and install additional wells. With respect to the soil remediation, please ensure you monitor and confirm the cleanup' s effectiveness through a post-cleanup sampling and analysis program. Normally, an investigation and cleanup of pollution which has degraded and threatens to degrade waters of the State would be overseen by the Central Valley Regional Water Quality Control Board (CVRWQCB). However, because of severe staff and funding shortfalls, we will be unable to provide technical oversight of your case at this time. Since we cannot oversee your case at this time, we recommend the following: (1) request project oversight from the San Joaquin County Environmental Health Department (the local implementing agency for the Underground Tank Program) and (2) follow the Tri-Regional Recommendations, including Appendix A (copies enclosed) and the "Leaking Underground Fuel Tank (LUFT) Field Manual : Guidelines for Site Assessment, Cleanup, and Underground Storage Tank Closure" . Although these documents were written for underground storage tanks, they are applicable to sites polluted with petroleum products, such as yours. The LUFT Manual can be purchased by calling the State Water Resources Control Board at (916) 739-4263.