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CaliforniaRefional Water Quality Antro/ Board <br /> Central Valley Region r <br /> Winston H.Hickox Steven T.Butler,Chair 5cr <br /> Serretaryfor _ Gray Davis <br /> Environmental Sacramento Main Office io Governor <br /> Protection Internet Address: h11P://"w.swrcb.Ca.gov/—rwgcb5 <br /> 3443 Routier Road,Suite A,Sacramento,California 95827-3003 <br /> Phone(916)255.3000•FAX(916)255-3015 <br /> 15 June 2000 <br /> 0 <br /> Mr. Bing Kirk <br /> Atherton Kirk Development Company <br /> 4502 Georgetown Place Suite 203 <br /> Stockton, CA 95205 <br /> ADDITIONAL GROUNDWATER ASSESSMENT LIME POND AREA, FORMER <br /> SPRECKELS SUGAR PLANT, MANTECA, SAN JOAQUIN COUNTY (Case No. 860) <br /> We have reviewed the Additional Groundwater Assessment Lime Pond Area, Former Spreckels Sugar <br /> Plant No. 2 submitted on 30 May 2000 on your behalf by Kleinfelder, Inc. The report documents an <br /> investigation undertaken to better assess the nature and extent of contamination in shallow groundwater <br /> related to the lime pond area. The following activities were completed: <br /> 1. Four new boreholes were drilled, logged and the data used to develop cross-sections to assess <br /> potential aquitards and vertical migration pathways. <br /> 2. In drilling the boreholes Groundwater samples were collected, analyzed with field test kits to <br /> assess vertical changes in water quality and to determine the optimum depth for well installation. <br /> Four monitoring wells were installed in the boreholes at the depths indicated. <br /> 3. Groundwater levels were measured in the four new wells and eleven existing wells and data was <br /> used to determine groundwater flow direction and gradient. <br /> 4. The new wells were developed and sampled for analysis of selected constituents. <br /> 5. Isocontour maps for Bicarbonate Alkalinity, Specific Conductivity, and Total Dissolved Solids <br /> \\ere constructed. <br /> The data collected is used to establish groundwater flow direction and gradient, vertical and lateral <br /> extent of groundwater impacts, and the presence of a clay bed aquitard that apparently limits vertical <br /> migration of contamination. Our comments on the report follow: <br /> 1. The use of constituent historic high value in the background well as background concentration <br /> for comparisons is inconsistent with the requirements of Title 27. Comparisons of constituent <br /> values should be based on an approved Water Quality Protection Standard. In Mr. Steve <br /> Rosenbaum's 2 November 1998 letter reviewing your Proposed Water Quality Protection <br /> Standard report, he expresses several concerns about that report: <br /> a. That the report does not set concentration limits for individual constituents at background <br /> levels; <br /> b. That in proposing concentration limits greater than background (CLGB), the report did <br /> not provide the economic analysis, nor did it demonstrate that cleanup was not <br /> economically or technically feasible as required in Title 27; <br /> California Environmental Protection Agency <br /> Ed Req rIed/'aper <br />