Laserfiche WebLink
Ms. Anne Ogrey <br /> Holly Sugar-Tracy • -2 - • 10 July 2008 <br /> needs to show that Site groundwater and soil will reach WQOs within a reasonable <br /> timeframe. Following the collection of the four consecutive quarters of groundwater <br /> data, Spreckels may evaluate the Site to determine whether the plume is defined and <br /> the groundwater and soil will reach WQOs within a reasonable timeframe. <br /> 3. The 7 December 2007 Regional Water Board letter included an attachment entitled <br /> Items to be Included in a Quarterly Monitoring Report. One of the listed items requires <br /> Spreckels to evaluate whether the pollutant plume is delineated. Monitoring well <br /> MW-FO-2 is downgradient of the release and continues to contain the highest <br /> concentrations of TPHd. In addition, grab groundwater samples collected in 2002 east <br /> of the Site (FOP-1R) contained TPHd concentrations of 79,000 Ng/L. Spreckels does <br /> not have any wells east of the Site. By 11 August 2008, Spreckels needs submit a <br /> work plan to define the lateral extent of the groundwater plume. In addition, future <br /> quarterly reports must include an evaluation of plume delineation. <br /> 4. Another item listed in the attachment to the 7 December 2007 letter was an isocontour <br /> pollutant concentration map. The Report does not include such a map. Spreckels <br /> needs to include isocontour concentration maps in future quarterly reports. In addition, <br /> the closure request needs to include isocontour maps for all four groundwater <br /> monitoring events. <br /> 5. Spreckels samples two wells associated with the wastewater treatment plant at the Site <br /> (WP-2 and WP-6). These wells are not shown on the groundwater contour figure. <br /> Spreckels needs to show the location of all wells sampled and monitored on Site <br /> figures. In addition, WP-2 and WP-6 well screens are flooded, so it is not clear whether <br /> these wells provide any useful TPHd data. <br /> 6. The analytical laboratory report includes the footnote F-3. This footnote is not defined <br /> in the laboratory report. In addition, the list of definitions includes the note H-1 , which is <br /> defined as "a lighter than water immiscible sheen/product is present." However, <br /> footnote H-1 is not used in the laboratory report. Spreckels needs to review the <br /> analytical laboratory footnotes and provide a revised laboratory report in the next <br /> quarterly report. The revised laboratory report needs to include accurate definitions for <br /> all footnotes. <br /> 7. The Report states a detection level of 1,000 pg/L is more reliable and consistent than <br /> the Regional Water Board staff requested level of 100 pg/L. Regional Water Board <br /> staff does not agree. As stated in the 4 March 2008 Regional Water Board staff letter, <br /> 100 pg/L is the taste and odor threshold Regional Water Board staff will use to evaluate <br /> the Site for closure. <br /> 8. The Report includes information on the three supply wells at the Site. The <br /> 4 March 2008 Regional Water Board staff letter requested Spreckels to prepare a table <br /> summarizing the information about all water supply wells in the area, which includes <br /> both the wells at the facility and any other federal, public, or private supply wells within <br /> one-half mile of the Site. Spreckels still has not provided the requested table. The <br /> Report includes an aerial photo of the location of the wells at the facility, but this photo <br /> is difficult to read and the locations of monitoring wells are not shown. The next <br />