SITE INFORMATION AND CORRESPONDENCE

Home Browse Search

Ms. Anne Ogrey Holly Sugar-Tracy -2 - 15 August 2007 Regional Water Board staff conducted a site visit on 17 October 2006 and discussed with you the current and future facility use and former leaking AGT area. You informed staff that the site no longer processes sugar from sugar beets, but instead provides storage of raw sugar for secondary processing into other types of sugars or molasses. Due to this change in processing requirements, there is no longer a facility need to use a diesel AGT for powering equipment and thus, it will not be repaired for reuse as a diesel AGT. During the site visit, Regional Water Board staff observed large uncovered soil piles around the tank that appeared to be stained and weathered. You told staff that these soil piles may be from scrapings around the AGT pit area. Our comments on the Investigation Report, Closure Report and site visit are presented below: 1. The Investigation Report states that "petroleum hydrocarbon affected soils were excavated, and a series of subsurface investigations were conducted between 1994 and 2002." Spreckels needs to summarize in the Closure Report the amount of soil excavated and any other site investigation activities conducted at the Site. 2. The Closure Report alludes to soil data collected at the Site, but does not include a table of soil data. All Site soil data needs to be tabulated in the Closure Report. 3. The table on Page 2 of the Closure Report lists the water level data for the AGT monitoring wells and includes data for 11 May 2005. However, the boring logs in the Investigation Report show these wells were not installed until 11 July 2005. This table needs to be corrected accordingly. 4. The Closure Report includes the field data sheets for 2006, but not those for 2005. In addition, the field data sheets include water level data for the AGT monitoring wells from 7 November 2006. These data are not included on the table on Page 2. It is also unclear whether the wells were sampled on 7 November 2006. Spreckels needs to provide the 2005 field sheets, clarify whether any sampling was conducted in November 2006, and include the November 2006 data on the table. 5. The Closure Report does not include laboratory analytical data for the 2006 groundwater sampling events. Spreckels needs to provide the laboratory analytical results for all groundwater samples collected. 6. The table on Page 3 of the Closure Report includes sample results for WP-2 and WP-6, but these wells are not shown on the figures or listed on the table on Page 2. Spreckels needs to provide a figure and table showing the locations of all monitoring wells and the well construction details of all wells used in the closure evaluation. 7. Figure 3 in the Closure Report provides the groundwater elevation and flow direction for the Site using the 20 June 2006 groundwater monitoring data and shows a southerly flow direction. However, previous water level data show a more northwesterly direction. Spreckels needs to prepare groundwater elevation and flow direction figures for all monitoring events and calculate groundwater gradient and flow direction for each event. 8. Regarding the large stained soil piles observed during the Regional Water Board site visit, Spreckels needs to notify the Regional Water Board of the source of these piles and submit a plan for their removal and disposal.