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A <br /> STATE OF CALIFORNIA PETE WILSON. Govemor <br /> CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD— <br /> CENTRAL VALLEY REGION <br /> 3443 ROUTIER ROAD, SUITE A a <br /> SACRAMENTO CA 95827-3098 4as <br /> PHONE: (916) 361-5600 <br /> FAX: (916) 361-5686 <br /> 6 December 1991 "o <br /> DEC 10 4011 <br /> Mr. G. Doug Dutton ENVIRONMENTAL HEALTH <br /> Environmental Engineer PERMIT/SERVICES <br /> Georgia-Pacific Corporation <br /> P. O. Box 1005605 <br /> Atlanta, Georgia 30348-5605 <br /> GEORGIA-PACIFIC CHEMICAL PACKAGING PLANT,TRACY, SAN JOAQUIN <br /> COUNTY (Case No. 2167) <br /> We have reviewed your 3 September 1991 letter and supporting technical data <br /> requesting our concurrence with your proposal to cease ground water cleanup <br /> activities at the Chemical Packaging Plant in Tracy. <br /> We have significant concerns regarding the cleanup goals of your corrective action <br /> program and the adequacy of the current monitoring system. Therefore, we cannot <br /> approve your proposal to cease ground water cleanup activities. <br /> Your letter contends that the concentrations of chloroform remaining in ground <br /> water pose no risk to human health or the environment based on comparison to <br /> the MCL of 100 gg/l for chloroform. Regional Board staff set a cleanup goal of 0.2 <br /> gg/1 for chloroform in a letter dated 14 February 1985. Based on recently published <br /> health based water quality criteria, Board staff now consider a cleanup goal of 5 gg/1 <br /> to be appropriate for this site. In addition, the recently revised Article 5 of Chapter <br /> 15 in California Code of Regulations, Title 23, Division 3, outlines the process by <br /> t tht.nt n b-ac goun`i can he <br /> which a CledrLi:p god. or concentration ..i.:it greater l::__- r <br /> kb_ <br /> established for a particular site. You may wish to review the new Article 5 and <br /> propose a concentration limit greater than background in accordance with Section <br /> 2550.4 of Chapter 15. Once the concentration limit for chloroform is established, the <br /> need for additional corrective action can be evaluated. <br /> The technical data provided by Brown and Caldwell Consultants indicate that <br /> monitoring wells nearest the impoundment have gone dry due to the prolonged <br /> drought in California. Chloroform concentrations have normally been highest in <br /> these wells. Due to these circumstances, the current monitoring system does not <br /> appear adequate to determine the chloroform concentration in ground water under <br /> the pond or demonstrate the effectiveness of the cleanup work. Therefore, we <br /> request that Georgia-Pacific demonstrate by 15 February 1991 that the current <br />