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Ualiforni .regional Water Vuality Cu. of Board <br /> a <br /> Central Valley Region 1 <br /> 1 <br /> Karl E. Longley,ScD,P.E:,Chair k <br /> Linda S.Adams 11020 Sun Center Drive#200,Rancho Cordova,California 95670-6114 Arnold <br /> Secretaryfor Phone(916)464-3291 •FAX(916)464-4645 Schwarzenegger <br /> Environmental h ttp://www.waterboards.ca.gov/centralval lev Governor <br /> Protection <br /> 16 March 2009 <br /> I ec'd CRA <br /> Mr. Nam Baek <br /> Glenn Springs Holdings, Inc. FEAR 1 14 2209 <br /> 5005 LBJ Freeway, Suite 1350 <br /> Dallas, TX 75244-6119 <br /> SULFOLANE LEACHABILITY TESTING RESULTS CLEANUP CRITERION, FORMER <br /> OCCIDENTAL CHEMICAL CORPORATION, 16777 HOWLAND ROAD, LATHROP, SAN <br /> JOAQUIN COUNTY <br /> The California Regional Water Quality Control Board, Central Valley Region (Regional Water <br /> Board) staff has reviewed the Sulfolane Leachability Testing Results and Sulfolane Soil Clean- <br /> up Criterion, PW-18 Vadose Zone Soil Investigation (Report), dated 25 February 2009. This <br /> Report was prepared on behalf of Glenn Springs Holdings, Inc. (GHSI) by Conestoga-Rovers <br /> & Associates (CRA). In the Report, CRA describes the soil sampling, analyses, and <br /> methodologies used to arrive at a soil cleanup goal for sulfolane in the area of well PW-18, <br /> and presents alternatives for cleaning up impacted soils. <br /> CRA derives a soil cleanup criterion from the leachability testing of impacted site soils from six <br /> samples collected during the 2008 investigation. The cleanup value is 8.6 milligrams per <br /> kilogram (mg/kg). Therefore, any soil concentrations of sulfolane above this amount could <br /> potentially result in a groundwater concentration greater than the health-based criterion for <br /> sulfolane (57 micrograms per liter, or pg/L), as a consequence of leaching from soil into <br /> groundwater. Based on our review of available human health and environmental regulatory <br /> criteria, we concur with the application of this cleanup criterion. <br /> Any potential remedy for the PW-18 area sulfolane impacts, including pilot testing and <br /> monitoring well installation, will require input from and close coordination with J.R. Simplot in <br /> order to minimize disruption to plant operations and hazards to workers. <br /> I have reviewed the Report and have the following specific comments: <br /> 1. CRA provides descriptions, advantages, and disadvantages of five proposed alternatives <br /> for remediation of the sulfolane in soils in the PW-18 area. In order for us to more fully <br /> evaluate the implementability, effectiveness, duration, reduction of pollutant mobility, and <br /> comparative costs of these options, we request that you prepare a Feasibility Study (FS) <br /> that provides this information in comparative detail. The FS will need to evaluate the <br /> cost to clean up sulfolane to background soil concentrations, or to non-detectable <br /> concentrations (i.e., less than 100 pg/kg), as well as the cost to clean up to the Water <br /> Quality Objective protective level. Please incorporate this information into the draft FS. <br /> The FS should contain results from for bench-scale testing or pilot studies of proposed <br /> California Environmental Protection Agency <br /> Ca Recycled Paper <br />