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MEMORANDUM V 2F CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD �CENTRAL VALLEY REGION' f 3443 Routier Road, Suite A Phone: (916) 361-56[� Sacramento, CA 95827-3098 Phone: Phone: 8-495-5600 TO: GORDON L. BOGGS FR0M: ELIZABETH A THAYER UG T Program Coordinator Associate. Engineer . F. WAYNE PIERSON Senior Engineer DATE: 8 April 1992 SIGNATURE: SUBJECT: APPLICATION FOR FACILITY PERMIT/WASTE DISCHARGE, 141 ,N0RTH EL DORADO STREET, STOCKTON, SAN JOAQUIN COUNTY I have reviewed the "Application for Facility Permit/Waste Discharge" and the Y file for 141 North El Dorado, Stockton, for completeness of the ground water investigation and effectiveness of the proposed remediation system. My review included a report, dated 27 July 1991, titled "Groundwater Remedial Action Plan" by RESNA/WaterWork (RWW) . The report contained a summary of previous investigations, the results of an aquifer pumping test, and a proposed ground water remediation system. The proposed ground water remediation system - consists of ground water extraction, treatment by activated carbon, and discharge by reinjection: The aquifer pumping test was .adequate and 'I have no- objection to the ground water remediation system in concept. However, the ground water investigation is incomplete, no Problem Assessment Report (PAR) has been submitted, and therefore, the application to discharge is premature. My comments follow: I. My review of the 27 July '1991report revealed:: 4' A. Reference is made to another report, dated 31 May 1991, titled "Summary of Soil Investigation/Soil Remediation Plan" also by RWW. This report is not in our file. B. . In April 1991, RWW drilled 7 -borings, two of which were converted ,to�monitoring, wells MW4 and MW5, and three were converted to vapor extractlon'`�we11s:-" 'A"vapoP 'ext'racti'on-feasibility' test-was"also ` = -� conducted. The boring logs and results of the vapor extraction feasibility test are reportedly in the missing 31 May 1991 report. .C. Figures showing the vertical and lateral extent of soil and ground water contamination were not included; D. The ground water plume is undefined in all directions but west, upgradient; E. The most downgradient well , near the intersection of El Dorado and Channel Streets, contained 600 ppb TPH in April 1991; F. A survey of wells within a mile radius was conducted -and a map showing the wells was included, however, . no information was k provided on the purposes of the wells, such as agricultural , municipal , domestic, etc. ;