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California Regional Water Quality coontrol Board <br /> Central Valley Region <br /> Robert Schneider,Chair <br /> Alan C.Lloyd,Ph.D. Arnold <br /> Secretaryfor Sacramento Main Officef p Schwarzenegger <br /> Environmental 11020 Sun Center Drive#200,Rancho Cordova,California 95670-6JAN 0 3 2005C Governor <br /> Protection - Phone(916)464-3291 •FAX(916)464-4645 <br /> http://www."terbouds.ca.gov/cmtralvalley SAN COUNTY <br /> ENVIRONMENTAL HEALTH DEPT <br /> ,'*1 December 2004 <br /> t <br /> Mr. Robert Garcia <br /> Leprino Foods, Inc. <br /> 1830 West 38a' Avenue <br /> Denver, CO 80217 <br /> REQUEST FOR CLEANUP PLAN, LEPRINO FOODS COMPANY, TRACY, SAN JOAQUIN <br /> COUNTY <br /> Staff of the Central Valley Regional Water Quality Control Board(Regional Board)has reviewed the <br /> 6 April 2004 Downgradient Groundwater Characterization and Monitoirng Well Installation (Report) <br /> and the 30 October 2004 Second and Third Quarters 2004 Semiannual Groundwater Monitoring Report <br /> (SAMR) submitted on your behalf by Geotrans, hie. for the groundwater diesel fuel pollution(TPHd) <br /> emanating from the Leprino Foods Company(Leprino)plant in Tracy. The Report contains the results <br /> of the downgradient investigation completed in February 2004, which attempted to define the <br /> downgradient extent of the TPHd plume by taking grab groundwater samples and constructing one <br /> monitoring well. The SAMR contains the results of groundwater monitoring that you completed during <br /> the second and third quarters of 2004. <br /> The groundwater investigation consisted of obtaining grab-groundwater samples from three borings. <br /> The sample from one boring, G-1, contained 190 ug/l TPHd. This boring was completed as MW-19 and <br /> subsequently sampled on 2 March 2004 and 3 September 2004. These samples contained 910 and 1,100 <br /> ug/l TPHd, respectively. These values are the same or higher than those found in monitoring wells RW-I <br /> and RW-2, which are about 115 feet closer to the source area. Therefore, Leprino has not defined the <br /> downgradient extent of the plume. <br /> The SAMR also shows that the cone of depression from recovery well EW-2 now extends to <br /> approximately Leprino's northern property line,but not to MW-19. The amount of free product in <br /> monitoring wells in the source area,MW-3 and MW-4, increased from 0.03 to 0.46 feet in MW-3 and <br /> from 0.32 to 1.1 feet in MW-4 from the second to the third quarter of 2004. The oil-water separator <br /> produced 11.5, 21.5 and 42 gallons of product during the first, second and third quarters of 2004. ' <br /> Therefore, it appears that recovery well EW-2 is performing as expected, is controlling the TPHd plume <br /> at the source area, and is continuing to remove product in the source area. <br /> hi our 29 January 2004 letter,we stated that the downgradient plume must be defined and documented <br /> with downgradient monitoring wells to facilitate development of a final cleanup plan. Leprino has failed <br /> to accomplish this. In the SAMR,you state that"vigorous natural attenuation processes (evaluated in a <br /> 2002 study at the site) will likely limit further plume migration." This is clearly not occurring in the <br /> California Environmental Protection Agency <br /> �a Recycled Paper <br />