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STATE OF CALIFORNIA—ENVIRONMENTAL PROTECTION AGENCY PETE WILSON,Gommor <br /> CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD— <br /> CENTRAL VALLEY REGION <br /> 3443 ROUTIER ROAD,SUITE A 6/1i <br /> SACRAMENTO,CA 95827-3098 <br /> PHONE: (916)255-3000 <br /> FAX: (916)255-3015 <br /> 29 March 1994 J <br /> MAR 3 1 1994 <br /> Mr. Stephen A. Johnson, Environmental Analyst ENVIRONMENTM.P7ALTH <br /> Heller Ehrman White & McAuliffe Attorneys PERMIT ISERvCES <br /> 333 Bush Street <br /> San Francisco, CA 94104-2878 <br /> MONITORING PROPOSAL— <br /> OGDEN WASTE TREATMENT SER VICES STOCKTON SOILS TREATMENT FACILITY <br /> I have reviewed your letter of 25 March 1994, in which you propose additional monitoring of <br /> ground water beneath the subject facility to determine whether releases from the former <br /> contaminated soil waste pile unit at the facility have degraded shallow ground water quality. <br /> While I support the construction of a new background monitoring well at the location shown on <br /> the map attached to your letter, there are several aspects of the letter with which I cannot agree. <br /> 1) On Page 2 of your letter, you state that I "clarified that the taste and odor criterion is not a <br /> major issue." That is not correct. I indicated that the main issue under the applicable <br /> monitoring and corrective action regulations in Chapter 15, Article 5 is whether there is <br /> evidence that the waste management unit has leaked, i.e. whether a change in water quality <br /> from background conditions is indicated by monitoring results. However, applicable water <br /> quality standards contained in the Basin Plan do prohibit adverse tastes and odors in waters <br /> designated for municipal and domestic supply. Ground waters beneath the Ogden facility are <br /> so designated. Short of direct evidence of adverse tastes and odors, the Regional Water <br /> Board must rely upon published taste and odor thresholds from the literature to gauge <br /> compliance with this standard. <br /> 2) On Page 2 of your letter, you claim that "TPH and TRPH are not good indicators of <br /> contamination at the site." This is not correct. The majority of the soils that were stockpiled <br /> in Ogden's waste pile came from the cleanup of the adjacent Tillie Lewis Cannery site. <br /> Benzene, toluene, ethylbenzene, and xylenes (BTEX) were not a significant component of <br /> the hydrocarbon fuel that was the subject of that cleanup effort. Petroleum hydrocarbons <br /> other than BTEX can cause significant water quality impacts, including adverse tastes and <br /> odors and toxicity. The enclosed table summarizes available measures of beneficial use <br /> impact for hydrocarbon mixtures and components. While I agree that TRPH measurements <br /> by themselves are not recommended for petroleum hydrocarbon characterization, when <br /> combined with TPH-gasoline and TPH-diesel measurements, the ranges of hydrocarbons <br /> present may be determined. TRPH, as measured by USEPA Method 418.1, provides <br /> measurements of hydrocarbons containing between approximately 10 and 35 carbons. TPH- <br /> gasoline by USEPA Method 8015 Modified (5030) covers hydrocarbons containing between <br />