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California 16ional Water Quality0ontrol Board <br /> ' a Central Valley Region ' `l <br /> Winston H.Hickoz Steven T.Butler, Chair <br /> Secretaryfor - `` [C Gray Davis <br /> Environmental 1. SacrameptQ VA1id frice Governor <br /> Protection Ircqj,4tltlre�s:'http://wwwswrcb.ca.gov/rwgc65 <br /> 3443 Routier Road,Suite A,Sacramento,California 95827-3003 <br /> Phone(916)255-3000•FAX(916)255-3015 <br /> 9 May 2000 <br /> Mr. George Pfandler <br /> Continental Grain Company <br /> North American Grain Division <br /> 222 South Riverside Plaza, Suite 1100 <br /> Chicago, IL 60606 <br /> SITE CHARA CTERIZA TION REPOR T, CONTINENTAL GRAIN COMPANY, 9504 S. HARLAN <br /> ROAD, FRENCH CAMP, SAN JOAQUIN COUNTY <br /> I have reviewed the 27 March 2000 Site Characterization Report submitted by Metcalf& Eddy, Inc. <br /> (M&E) for the ContiGroup Companies, Inc. (CGCI) French Camp Elevator facility(site). I have the <br /> following comments regarding this report: <br /> 1. The Fourth Edition of the Water Quality Control Plan for the Sacramento River and San Joaquin <br /> River Basins (Basin Plan) states in part: <br /> "An investigation of soil and ground water to determine full horizontal and vertical extent of pollution is <br /> necessary to ensure that cleanup plans are protective of water quality. The goal of the investigation shall be <br /> to determine where concentrations of constituents of concern exceed beneficial use protective levels(water <br /> quality objectives)and, additionally,where constituents of concern exceed background levels(the zero- <br /> impact line). Investigations shall extend off-site as necessary to determine the full extent of the impact." <br /> The Site Characterization Report does not satisfy this requirement. CGCI needs to investigate the <br /> full horizontal and vertical extent of pollution to the zero-impact line as stated in the Basin Plan. <br /> 2. M&E incorrectly cites the maximum contaminant level (MCL) for carbon tetrachloride. The <br /> California Department of Health Services MCL for carbon tetrachloride, which is a known human <br /> carcinogen, is 0.5 µg/1, not 5 µg/1. Based on the California Environmental Protection Agency <br /> Cacer Potency Factor as a Drinking Water Level (one-in-a-million cancer risk), the water quality <br /> objective for carbon tetrachloride is 0.23 µg/l. Since the laboratory method reporting limit for <br /> carbon tetrachloride is currently higher than the most stringent water quality objective, the water <br /> quality objective defaults to the laboratory method reporting limit (0.5 µg/1). <br /> 3. In addition to carbon tetrachloride, groundwater samples contain chloroform, tetrachloroethene, <br /> 1,2-dichloroethane, 1,2-dichloropropane, and dibromochloromethane above their respective water <br /> quality objectives. CGCI needs to investigate and remediate all pollutants that exceed water <br /> quality objectives. <br /> 4. M&E did not include several wells when estimating the groundwater elevation contours. Future <br /> groundwater contour maps need to include all available groundwater data. <br /> California Environmental Protection Agency <br /> �a Reevcled Paper <br />