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California Regional Water Quality C•trol Board <br /> Central Valley Region <br /> Winston H.Hickox Robert Schneider, Chair Y <br /> Gra Davis <br /> Secretaryfor Sacramento Main Office Governor <br /> Environmental Internet Address: h //www.sw eb.ca. ov/-m cb5 °`I;' <br /> Protection 8 9 C] ��I� <br /> 3443 Reader Road,Suite A,Sacramento,California 95827-3003 ��.�� C, \� Icy <br /> Phone(916)255-3000•FAX(916)255-3015 <br /> MAY 3 1 2002 <br /> 29 May 2002 ENVIRONMENT HEALTH <br /> PERMIT/SERVICES <br /> Mr. Robert Garcia <br /> Leprino Foods, Inc. <br /> 1830 West 38d'Avenue <br /> Denver, CO 80217 <br /> FOURTH QUARTER 2001, FIRST QUARTER 2002 AND ANNUAL GROUNDWATER <br /> MONITORING REPORT, LEPRINO FOODS COMPANY, TRACY, SAN JOAQUIN COUNTY <br /> We have reviewed the Fourth Quarter 2001, First Quarter 2002 And Annual Groundwater Monitoring <br /> Report, Leprino Foods Company, Tracy, San Joaquin County (Report), prepared by GeoTrans, Inc. and <br /> received 26 April 2002. The Report is required under the Regional Water Quality Control Board, <br /> Central Valley Region (Regional Board)Monitoring and Reporting Program (MRP)Number 5-00-833. <br /> The Report shows that maximum petroleum hydrocarbon separate phase product (SPP) in monitoring <br /> well MW-4 peaked in December 2001 at 1.02 feet, which is the greatest thickness since 1997. Total <br /> Petroleum Hydrocarbon as Diesel (TPH-d)concentration in groundwater at downgradient property line <br /> monitoring well RW-2 continues to increase, and was 910 gg/L in March 2002. The Report states that <br /> dissolved phase hydrocarbons, which have migrated past the northern property boundary, have decreased <br /> since extraction wells RW-4A and RW-5A were restarted in 2000. The Report concludes that continued <br /> groundwater capture and natural attenuation should result in lower TPH-d concentrations in the <br /> downgradient boundary monitoring wells. <br /> The Report requests that, due to declining concentrations, RW-4A be evaluated for shutdown, and that <br /> negotiations begin to define remedial objectives for cessation of treatment system operations. <br /> General Comments: <br /> 1. The Report does not provide an evaluation of capture by additional extraction wells for the portion of <br /> the TPH-d plume now migrating offsite, but states that existing extraction wells and natural attenuation <br /> will reduce concentrations at the property line. The Report, however, offers no evidence that natural <br /> attenuation, including biodegradation is occurring at the site. <br /> In our letter dated 19 November 2001, we questioned whether hydraulic capture was occurring near the <br /> northern property boundary of the site. We stated,that if the analytical results of monitoring two <br /> additional quarters (December 2001 and March 2002) showed that the contamination levels are <br /> rebounding, we would require an evaluation to determine whether restarting extraction wells RW-1 and <br /> California Environmental Protection Agency <br /> ed Recycled Paper <br />