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CaliforniaSegional Water Quali*Control Board <br /> Central Valley Region <br /> Robert Schneider, Chair - <br /> Terry Tamminen Sacramento Main Office <br /> Internet Address: http://w .sw b.ca.gov/wgcb5 Arnold Schwarze <br /> Secretary for 11020 Sun Center Drive#200 Rancho Cordova,CA 95670-6114 Governor <br /> Environmental Phone(916)464-3291 Fax(916)4644797 <br /> Protection RECEIVED 5 March 2004 <br /> Mr. Daniel Decker <br /> ContiGroup Companies, Inc. MAR 0 9 2004 <br /> 277 Park Avenue ENVIRONMENT HEALTH <br /> New York, NY 10172 PE /Sti&C l! <br /> REVIEW OF ANNUAL MONITORING REPORT, CONTIGROUP COMPANIES,INC., <br /> 9504 HARLAN ROAD, FRENCH CAMP, SAN JOAQUIN COUNTY <br /> Staff of the Central Valley Regional Water Quality Control Board (Regional Board)has reviewed the <br /> 28 January 2004 2003 Annual Groundwater Monitoring Report (Annual Report) submitted by Haley & <br /> Aldrich, Inc. on behalf of Huff&Huff, Inc. for the ContiGroup Companies, Inc. (ContiGroup) French <br /> Camp Grain Elevator facility at 9504 South Harlan Road in French Camp. The Annual Report discusses <br /> concentrations trends and summarizes investigative activities conducted in 2003. The discussion of the <br /> fourth quarter sampling was submitted in a 31 October 2003 report. <br /> The Annual Report states that the size of the groundwater plume appears to be relatively stable,but the <br /> figures provided in the Annual Report do not support this conclusion. ContiGroup needs to contour <br /> concentrations to nondetect and provide the rationale for the conclusion that the plume size is stable. <br /> ContiGroup has requested a meeting with Regional Board staff to review remedial goals for the site and <br /> to discuss remedial technologies. It is not clear why this is being requested only four months after Waste <br /> Discharge Requirements (WDRs) Order No. R5-2003-0166 were issued for the Hydrogen Releasing <br /> Compound®injection pilot study. Furthermore, the findings of the WDRs discuss the Water Quality <br /> Control Plan for the Sacramento River and San Joaquin River Basins, Fourth Edition (Basin Plan), <br /> State Water Resources Control Board (SWRCB) Resolution No. 68-16 (the"Antidegradation Policy"), <br /> and SWRCB Resolution No. 92-49 (Policies and Procedures for Investigation),which provide <br /> information on remedial goals. <br /> If the above references do not provide the information you need, by 8 April 2004, please provide <br /> multiple dates and times when you are available to meet or have a conference call and specifically what <br /> you wish to discuss. The first quarter monitoring report is due by 30 April 2004, which should include <br /> figures contoured to nondetect and a discussion of the plume size stability. If you have any questions, <br /> you may contact me at(916) 464-4719 or lewisd@rb5s.swrcb.ca.gov. <br /> &�A& <br /> DEVRA LEWIS <br /> Environmental Scientist <br /> cc: Mr. Jeff Wong, San Joaquin County Health Department, Stockton <br /> Ms. Linda Huff, Huff&Huff, LaGrange, Illinois <br /> Mr. Bill Zech, French Camp Grain Elevator, French Camp <br /> Mr. Joe Weidmann, Haley& Aldrich, Inc., San Diego <br /> California Environmental Protection Agency <br /> Qi Recycled Paper <br />