SITE INFORMATION AND CORRESPONDENCE

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Margaret Lagorio From: Margaret Lagorio Sent: Thursday, November 08, 2001 12:03 PM To: 'KEPetryna@equiva.com' Subject: 3011 Benjamin Holt, Stockton Karen, I have discussed this site with Michael Infurna and reviewed our file information. MTBE was first evidenced at this site in February 1997. According to the California Code of Regulations the responsible parties are to submit quarterly reports that include proposed cleanup actions and a time schedule for implementing the proposed actions. Since the investigation at this site was not progressing in a timely manner, PHS/EHD provided a Problem Assessment Report(PAR)submittal date of December 7, 2001, in our letter dated February 27, 2001, and detailed that the PAR was to describe the lateral and vertical extent of the problem and propose remedial actions. That letter also gave a work plan submittal date of March 26, 2001. The work plan was not submitted until June 25, 2001. PHS/EHD staff and CVRWQCB staff met with you and your consultants to discuss all the Shell and Texaco sites in San Joaquin County on June 19, 2001, because PHS/EHD staff do not feel that work on these sites progresses in a timely manner. In that meeting it was again discussed that the PAR for this site was due. The work plan submitted June 25, 2001,was approved by PHS/EHD on June 29, 2001, and the work was completed on July 30, 2001. The report of that work was submiited to PHS/EHD on September 17, 2001. Unfortunately, the lateral and vertical extent of contamination was not defined by that scope of work and you submitted another work plan on October 15, 2001,which PHS/EHD approved with conditions on October 17, 2001. The October 2001 work plan activities are scheduled to be performed December 10-14, 2001. You will not be able to submit a PAR by December 7, 2001, since you have not defined the extent of the contamination yet, so you have asked for an extension for submittal of the PAR. PHS/EHD will not extend the PAR submittal date, but will not initiate non compliance action if the PAR is submitted by January 14, 2002. Please evaluate now if you will need to install monitoring wells to confirm your CPT data and propose and plan for their installation soon after or at the same time that you are performing the additional CPT work in December 2001. In addition, consider moving CPT14 north of MW 1 to investigate the vertical extent of contamination downgradient of that well which has evidenced MTBE in the shallow groundwater in that area. Other responsible parties have combined reports and work plans to complete investigations quicker and you should consider this for all your sites. I hope this clarifies our position. Margaret 1