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STATE OF CALIFORNIA • • PETE WILSON, Governor CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD— ng, "w CENTRAL VALLEY REGION d 3443 ROUTIER ROAD, SUITE A ' + ryryryTV, s.N SACRAMENTO, CA 95827-3098d" PHONE: (916) 361-5600 + ' FAX: (916) 361-5686 OCT 15 1:7,q1 10 October 1991 Ms. Eleanor Ratliff San Joaquin County Public Health Services Environmental Health Division P.O. Box 2009 Stockton, CA 95201 RECOMMENDED NOTICE OF VIOLATION, GEWEKE, 16 SOUTH CHEROKEE LANE, LODI, SAN JOAQUIN COUNTY I have reviewed the Geweke file and have the following comments: A. In the PES Environmental "Progress Report", dated 1 July 1991, PES states that "quarterly monitoring of all 14 wells is unnecessary to effectively monitor groundwater conditions at the site. Until any groundwater remediation system is operational , quarterly monitoring of the five perimeter wells (MW-6, MW-10, MW-11, MW-12 and MW-13) should be adequate to monitor for any plume migration." In a telephone conversation with you, on 13 August 1991, 1 agreed that it did not seem necessary to sample all 14 wells quarterly but that MW-4 and MW-2 or MW- 7 be included in the quarterly sampling. In your letter to Geweke, dated 19 August 1991, you included my comments on quarterly sampling. Unfortunately, I was in error. Only the Regional Board Executive Officer, William H. Crooks, may amend C&A requirements. Until the C&A is modified, all wells must be sampled quarterly and the results submitted quarterly as specified in the C&A. B. In a telephone conversation with Keith O'Brien, of PES, on 6 September 1991 , 1 agreed that additional aquifer testing may be delayed until it has been determined that infiltration or injection of treated ground water is the proposed method of disposal . The aquifer data that has already been provided is adequate at this time. However, the final remediation plan should address additional aquifer testing if subsurface disposal is proposed. C. We also recommend that Geweke consider initiating soil remediation as soon as possible. Without some sort of soil remediation, the proposed ground water remediation system may take years to accomplish due to continuing ground water contamination from contaminated soil . Excavation of the former pump islands and/or soil venting during the current drought conditions (or some other soil remediation method) will facilitate ground water cleanup and be consistent with the intent of the C&A. A soil remediation proposal be addressed in the final remedial plan.