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California Regi nal Water Quality Control Board f:-.,... <br /> vCentral Valley Region <br /> Robert Schneider,Chair <br /> Winston H.Hickox Gray Davis <br /> Secretaryfor Sacramento Main Office (•j$py$rnor. <br /> Environmental Internet Address: http://www.sweb.ca.gov/—mgcb5 <br /> Protection 3443 Routier Road,Suite A,Sacramento,California 95827-3003 <br /> Phone(916)255-3000•FAX(916)255-3015 OCT 2 0 2003 <br /> ENVIRONMENT HEALTH <br /> 17 October 2003 PERMIT/SERVICES <br /> Mr. Robert Garcia <br /> Leprino Foods, Inc. <br /> 1830 West 38t11 Avenue <br /> Denver, CO 80217 <br /> DOWNGRADIENT GROUNDWATER CHARACTERIZATION WORKPLAN,LEPRINO FOODS <br /> COMPANY, TRACY, SAN JOA Q UIN CO UNTY <br /> Staff of the Central Valley Regional Water Quality Control Board(Regional Board) has reviewed the 22 <br /> September 2003 Work Plan for Downgradient Groundwater Quality Characterization (Work Plan) <br /> submitted on your behalf by Geotrans, Inc. to characterize the extent of downgradient diesel fuel <br /> pollution emanating from the Leprino Foods Company(LFC)plant in Tracy. Two existing monitoring <br /> wells,RW-1 and RW-2, are located on the northern, downgradient property line and contain total <br /> petroleum hydrocarbons in the diesel range (TPHd). The Work Plan proposes a strategy to determine the <br /> extent that TPHd has migrated off site and locate a downgradient monitoring well. The investigation <br /> strategy would utilize Geoprobe® sampling technology to advance borings downgradient of RW-1 and <br /> RW-2. Soil and groundwater samples from the borings would be screened in the field for evidence of <br /> TPHd based on visual inspection and odor. If there is evidence of TPHd, another boring will be <br /> advanced further downgradient. At the point where there is no odor or visual evidence of TPHd a <br /> monitoring well will be installed. <br /> We have the following comments on the Work Plan: <br /> 1. Page 1 refers to the downgradient monitoring well as a"point-of-compliance"monitoring well. The <br /> term"point-of-compliance"has a specific meaning under California Code of Regulations Title 27, <br /> Section 20005 et seq., and is not applicable in this case. LFC needs to determine how far TPHd has <br /> migrated from its property and install sufficient monitoring wells to document the extent of the <br /> plume and the effectiveness of remediation efforts. <br /> 2. Page 2 of the Work Plan states that borings will be located on public land and easements where <br /> necessary (emphasis added). The borings should be located on public land and easements wherever <br /> possible. <br /> 3. Page 2 of the Work Plan states that groundwater elevations in the existing monitoring wells will be <br /> surveyed relative to equilibrated groundwater elevations in the Geoprobe® .borings,but does not. <br /> specifically say how LFC will determine that the groundwater level is equilibrated. Because the <br /> California Environmental Protection Agency <br /> cd Recycled Paper <br />