SITE INFORMATION AND CORRESPONDENCE

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MEMORANDUM CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD - CENTRAL VALLEY REGION 3443 Routier Road, Suite A Phone: (916) Z55-3000 Sacramento, CA 95827-3098 CALNET: 8-4943000 TO: GORDON L. BOGGS FROM: ELIZABETH A. THAYER UGT Program Coordinator Associate Engineer DATE: 19 February 1993 SIGNATURE: SUBJECT: MEETING, 16 SOUTH CHEROKEE LANE, LODI, SAN JOAQUIN COUNTY A meeting was held 18 February 1993, to discuss rescinding the existing Cleanup and Abatement Order (C&A) No. 90-702 and issuing a new C&A. A meeting agenda was mailed to the Gewekes in a letter dated 28 January 1993 and a draft C&A was mailed on 11 February 1993. Attached are an attendance list and memorandum containing my comments on the status of the site prior to the meeting and the Final Remediation Plan in particular. The meeting began with a discussion of the Problem Assessment Report (PAR) and Final Remediation Plan (FRP) . Board staff stated that the PAR and FRP were incomplete and, therefore, the Gewekes are out of compliance with the C&A. The deficiencies of the reports were discussed with Mr. Werner during the meeting and the attached agenda and memorandum explain the inadequacies of the documents in more detail . Mr. Werner expressed on several occasions that he was concerned that regulatory staff had not responded to Geweke's reports and submittals in a timely manner. He stated that he was ready to get to work cleaning up the site. Board staff explained that before cleanup begins, it is more efficient and cost-effective to define the vertical and lateral extent of soil and ground water contamination. Once this is done, the best remediation options for the site can then be chosen and designed. Remediation can begin before the full extent of contamination is known. However, this may end up being more costly in the long run if the system has to be rebuilt, expanded, modified, or scrapped for another method in order to encompass the entire contaminated area. Mr. Werner reported that Armour Oil has some responsibility for cleanup of this site as the former tank owner and operator. Board staff stated that Geweke's attorneys must submit in writing to the Board, any information or documentation supporting this contention. Once we have received the information, we can consider adding Armour to the C&A. Board staff stressed that this is a side issue that does not affect the C&A time schedule and compliance requirements. The Gewekes and Geweke Land Development and Marketing are named in the C&A and are responsible for complying with the requirements. Therefore, Board staff stated that we need a letter from the Gewekes stating that Mr. Werner is authorized to represent them at meetings and sign authorization letters. The new C&A will require that all reports submitted to the Board be accompanied by an authorization letter from the responsible parties.