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CaliforniaWgional Water Quality Coil Board <br /> Central Valley Region <br /> Karl E. Longley,SCD,P.E.,Chair ' x -' <br /> Linda S.Adams I "��--a� <br /> Secretaryjor I' t, ' -. =i, Arnold <br /> Environmental 11020 Sun Center Drive#200,Rancho Cordova,Califomia 95670-6114 Schwarzenegger <br /> Protection Phone(916)464-3291 •FAX(916)464-4645Au C 0 ���$ Governor <br /> http://www.waterboards.ca.gov/centralval ley <br /> ENVIRO-MOIEl+i i nE/'' i <br /> Ms. Anne Ogrey PERM!TISERViCE- <br /> Spreckels Sugar Company 19 August 2008 <br /> P.O. Box 60 <br /> Tracy, CA 95378 <br /> SECOND QUARTER 2008 MONITORING REPORTAND WORK PLAN— FORMER HOLLY <br /> SUGAR FACILITY, TRACY, SAN JOAQUIN COUNTY <br /> California Regional Water Quality Control Board, Central Valley Region (Regional Water <br /> Board) staff reviewed the following reports: <br /> • 25 July 2008 Second Quarter Monitoring Evaluation (Second QMR) <br /> • 11 August 2008 Workplan (Work Plan) <br /> John Minney (Minney) submitted these reports on behalf of Spreckels Sugar Company <br /> (Spreckels) for the former Holly Sugar facility on Holly Drive in Tracy (Site). <br /> The Site is the location of a former sugar beet facility. In November 1990, about 500 to <br /> 800 gallons of No. 6 fuel oil spilled from a 420,000-gallon aboveground storage tank (AGT) in <br /> the northeast corner of the facility. Spreckels emptied the tank in 1997 and no longer <br /> operates it. <br /> Spreckels conducted the second quarter 2008 monitoring event on 11 June 2008. The <br /> groundwater flow direction was to the southwest. Total petroleum hydrocarbons as fuel oil <br /> (TPHfo) were detected in all three Site wells at concentrations ranging from 380 micrograms <br /> per liter (pg/L) to 2,000 Ng/L. <br /> Spreckels prepared the Work Plan in response to the Regional Water Board staff 10 July 2008 <br /> letter requesting a work plan for lateral plume definition. The Work Plan proposes drilling one <br /> soil boring in the location of previous soil boring FOP-1 R and installing a monitoring well. <br /> Spreckels states that if there is an indication of petroleum hydrocarbons in the soil at the <br /> location of FOP-1 R, the boring will be moved east until a location with no traces of petroleum <br /> hydrocarbons is found. The monitoring well will be installed in the location of clean soil. If the <br /> new monitoring well confirms the detections at soil boring FOP-1 R, Spreckels will add the well <br /> to the monitoring program. <br /> Our comments are included below: <br /> 1. The Second QMR continues to state there are sufficient monitoring data at this time for <br /> Regional Water Board staff to evaluate the Site for closure. Spreckels has made this <br /> statement in every quarterly report. Regional Water Board staff does not agree. In <br /> order for Regional Water Board staff to evaluate the Site for closure, Spreckels needs <br /> to show that Site groundwater and soil will reach water quality objectives (WQOs) within <br /> California Environmental Protection Agency <br /> 0 Recycled Paper <br />