SITE INFORMATION AND CORRESPONDENCE

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Meeting Memorandum - 2 - 19 February 1993 16 South Cherokee, Lodi We discussed the time schedule in the draft C&A. Mr. Werner. stated that he had no problem with the time schedule as written. Board staff stressed that now is the time to adjust the dates so that the Gewekes could remain in compliance with the requirements of the new C&A. Board staff emphasized that a work plan must be submitted and the full extent of soil and ground water contamination must be defined before the FRP is submitted by 30 May 1993. That is a lot of work to do in a short time and we will not accept a second work plan. The contamination must be defined before we will accept the FRP as complete. Submittal of an incomplete FRP or missed compliance dates constitute noncompliance with the C&A. We then took a short break so that Mr. Werner could confer with his consultant to consider the time needed to complete the required work. We agreed to extend the dates as follows: C&A REQUIREMENT DRAFT C&A DATES REVISED C&A DATES Submit Work Plan 15 March 1993 15 April 1993 Implement Work Plan 1 April 1993 1 May 1993 Submit FRP 30 May 1993 30 July 1993 Initiate Cleanup 15 July 1993 15 October 1993 Begin Remediation 15 August 1993 15 November 1993 We then discussed the monitoring reports. Board staff stated that the Quarterly Reports submitted since the Monitoring and Reporting Program (MRP) was issued on 18 December 1991, have not included analytical results for all the required constituents. Failure to comply with the MRP is a violation of the C&A and, therefore, Geweke is out of compliance. In addition, a number of wells have not had ground water samples collected and analyzed for 2 years because the annual sampling event occurs when the wells are dry. These wells have had water in them during other quarters and could have been sampled. Lack of data from these wells limits knowledge of the site and extends the amount of time to complete the investigation and cleanup. Board staff pointed out that the draft C&A contains a new monitoring program requiring quarterly sampling of all 13 existing wells and any wells installed at a later date. The same constituents must be analyzed as in the previous MRP. Mr. Werner was adamant that Geweke would sample only 5 wells per quarter. (The current monitoring schedule includes 7 wells that are sampled quarterly and all wells are sampled annually. ) He gave no justification for this number of wells beyond the cost of sampling. He stated that he would contact his attorneys and Regional Board Members if Board staff persisted in requiring monitoring of all wells. Board staff repeated that the existing monitoring program is inadequate and Geweke has not complied with the required schedule. Mr. Werner stated that he was unprepared to discuss changes to the monitoring program other than insisting that sampling 13 wells quarterly was too much. Board staff stated that the agenda for this meeting included discussion of the monitoring program. (Prior to the meeting, Mr. Werner had received a copy of the agenda and draft C&A which included the proposed monitoring schedule. )