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MEMORANDUM CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD - CENTRAL VALLEY hone: ( REGION GOO 3443 Routier Road, Suite A ATSS Phone: 8-4943000 Sacramento, CA 95827-3098 TO: GORDON L. BOGGS FROM: ELIZABETH A. THAYER te Engineeria UGT Program Coordinator Assoc � �•� DATE: 19 February 1993 SIGNATURE: SUBJECT: CLEANUP JOAQAND ABATEMENT ORDER 90-702 (C&A), 16 SOUTH CHEROKEE LANE, LODI, The C&A issued 5 March 1990, required submittal of quarterly reports, a work plan to define the contamination by 23 March 1990, implementation of the work plan by 13 April 1990, a Problem Assessment Report (PAR) by 25 May 1990, a Final Remediation Plan (FRP) by 29 June 1990, and implementation of the FRP by 24 August 1990. The work plan was submitted on time but the work was implemented in July 1990 and failed to define the extent of ground water contamination. Geweke missed the 13 April 1990 date to implement the work plan and never got back on schedule. The lateral extent of ground water contamination was eventually defined and a PAR was submitted 31 July 1991 . After I reviewed the PAR and recent documents in the file, in a memo to you, dated 16 August 1991 I reported that the PAR was incomplete. My concerns were as follows: 1 . No quarterly reports had been submitted since the C&A was issued (from April 90 to April 91, five quarters) ; 2. It was proposed to discharge treated ground water to the sewer. County staff informed me that it was unlikely that the City would agree to sewer discharge. I recommended that Geweke consider other disposal options, including reinjection, and that if they had to reinject, then additional aquifer or pumping tests were necessary; 3. No soil remediation was proposed. I discussed these concerns with County staff by telephone and in a letter from the County to Geweke, dated 28 August 1991, County staff conveyed my concerns about the soil and ground water remediation systems and required submittal of a draft FRP by 15 September 1991 . In a letter to the County, dated 10 October 1991, Board staff recommended issuance of a Notice of Violation for failure to submit quarterly reports. The letter also recommended that Geweke submit a soil remediation plan as soon as possible. The County issued a Notice of Violation, dated 28 October 1991, requiring Geweke to submit quarterly reports, submit an FRP by 2 January 1992, and address soil remediation in the FRP. Monitoring and Reporting Program 90-702 (MRP) , superseding the monitoring program in the C&A was issued 18 December 1991. Quarterly reports have been submitted on time since the MRP was issued, however, lead, ethylenedibromide, 1,1-dichloroethane, and 1,2-di chloroethane have not been included in the analyses as required. Some wells are only monitored annually but are dry part of the year. They have not been sampled when they contained water in March or