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California&gional Water Quality Corapl Board <br /> Central Valley Region <br /> v Robert Schneider,Chair <br /> Linda S.AdamsArnold <br /> Secreraryfor - Sacramento Main Office Schwarzenegger <br /> Environmental 11020 Sun Center Drive#200,Rancho Cordova,California 95670-6114 Governor <br /> Protection Phone(916)464-3291 •FAX(916)464-4645 <br /> hitp://www.waierboards.ca.gov/centralvalley r� (('�n�,' <br /> 7 December 2007 DEC 1 0 2007 <br /> Ms. Anne Ogrey ENVIRONMENTREALT <br /> Spreckels Sugar Company FERMITISERVICES H <br /> P.O. BOX 60 <br /> Tracy, CA 95378 <br /> ABOVEGROUND STORAGE TANK RELEASE CLOSURE— FORMER HOLLY SUGAR <br /> FACILITY, TRACY, SAN JOAQUIN COUNTY <br /> California Regional Water Quality Control Board, Central Valley Region (Regional Water <br /> Board) staff reviewed the 31 October 2007 Aboveground Storage Tank Release Closure <br /> (Report). John Minney (Minney) submitted the Report 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 800 <br /> gallons of No. 6 fuel oil spilled from a 420,000-gallon aboveground storage tank (AGT) in the <br /> northeast corner of the facility. Spreckels emptied the tank in 1997, and it is no longer in <br /> operation. <br /> Spreckels installed groundwater monitoring wells WP-2 and WP-6 at the Site to monitor the <br /> process wastewater ponds north and west of the AGT. Spreckels conducts quarterly <br /> groundwater monitoring of these wells separately from the AGT investigation as part of <br /> Regional Water Board Waste Discharge Requirements Order No. R5-2003-0050. <br /> In 2005, Spreckels installed groundwater monitoring wells MW-FO-1 through MW-FO-3 to <br /> assess the lateral extent of total petroleum hydrocarbons (TPH) in the vicinity of the AGT. <br /> Spreckels sampled these wells on 12 July 2005, 11 October 2005, and 20 June 2006. All <br /> three monitoring wells contained TPH in July 2005, and MW-FO-2 contained the maximum <br /> TPH concentration at 2.8 milligrams per liter (mg/I). In the June 2006 sampling event, none of <br /> the AGT monitoring wells contained TPH above the reporting limit of 0.05 mg/l. <br /> Spreckels requests closure because it says the beneficial uses of groundwater have not been <br /> threatened by the fuel oil release and all site wells were below detection limits during the last <br /> sampling event. <br /> Regional Water Board staff do not concur with closure of the Site at this time. Our comments <br /> are presented below: <br /> 1. On 23 February 2005, Spreckels submitted the Additional Investigation Work Plan <br /> (Work Plan). The Work Plan proposed to install three monitoring wells and conduct <br /> quarterly sampling events for four consecutive quarters. On 13 April 2005, Regional <br /> Water Board staff approved the Work Plan and requested Spreckels to submit quarterly <br /> California Environmental Protection Agency <br /> Qa Recycled Paper <br />