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. A , MEMORANDUM CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD - CENTRAL VALLEY REGION 3443 Routier Road, Suite A Phone: (916) 361-5600 Sacramento, CA 95827-3098 ATSS Phone: 8-495-5600 TO: FILE FROM: Jean McCue Water Resource Control Engineer DATE: 10 May 1991 SIGNATURE: � SUBJECT: MEETING MITH RE-MANUFACTURING, LTD. AND 29 APRIL 1991 INSPECTION. A meeting was held at this office on 29 April 1991. Stanley Moore (Re-Manufacturing), Nora Kataoka (consultant for Mr. Moore, Water Work Corporation), Greg Vaughn (Regional r Beard;,-and I were present. We discussed Ms. Kataoka's letter (received 17 April 1991) responding to my 28 February 1991 and 19 February 1991 memorandums regarding Kleinfelder's Closure Plan and Soil and Ground Water Assessment Report. We also discussed the Notice of Violation that enclosed the two memorandums. Mr. Moore must submit all necessary information to complete the HAR and have a closure plan approved and implemented by 1 June 1991 in order to avoid paying the balance of the original civil liability (Order No. 90-236) , in the amount of $99,500. Prior to the meeting, Mr. Moore collected and analyzed additional samples in the TPCA surface impoundment and Mormon Slough. Results presented at the meeting indicated levels of total lead in the slough, ranging from 170 to 899 mg/kg upstream of the surface impoundment and 77 to 368 mg/kg downstream of the surface impoundment. All were below the Total Threshold Limit Concentration (TTLC) of 1,000 mg/kg. Twelve samples were collected from the surface impoundment. However, they did not define the lateral and vertical extent of the soil contamination. We did not receive a copy of the results, location map, or chain of custody at the meeting. Mr. Moore contends that the impoundment was constructed from materials dredged out of the slough and, therefore, the slough is the source of the lead contamination. He intends to prove that the soil contamination in the impoundment walls is from the slough and surrounding area and was not contaminated from discharges to the surface impoundment. Mr. Moore also wants to show that the entire area, including the slough, is high in lead in order to justify a higher cleanup level for the surface impoundment. -Mr. 'Vaughn stated that Mr. Moore must submit evidence to support his claim that the entire area is contaminated. He stated that sufficient data must be submitted to define the lateral and vertical extent of the soil contamination in and around the i surface impoundment, in order for the closure plan to be approved. It was determined that more sampling was required to prove Mr. Moore's case. This will include analyses for both total and soluble lead. The lateral extent of the soil contamination should either show the surface impoundment contamination is localized or that the soil contamination is so extensive (i .e. extends throughout the site and off site) , that it could not have been caused by discharges of wastes to the surface impoundment. Since time is very limited (the closure plan must be approved and implemented by I June 1991) we stressed the importance of collecting sufficient samples to avoid the need for additional sampling after the results come back from the lab. Ms. Kataoka said she would FAX the Board a sampling plan prior to collecting additional samples, for our approval .