SITE INFORMATION AND CORRESPONDENCE_CASE 2

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S. Paul Verma, P.E. J City of Tracy Public Works Department - 2 - 12 April 2000 4. Ground water monitoring wells will be installed and monitored per MRP 94-216. The City may request a revision the MRP(modification of the monitoring parameters and sampling frequency) once the existing water quality concentrations are established; 5. Site closure- Cell soil sampling program to verify clean closure is adequate; The confirmation sampling plan to demonstrate all waste materials were removed from the 16 cells is described as one sample collected from the bottom of each cell and a composite of the four side walls in each cell. Sample constituents will be consistent with WDR 94-216. 6. A final closure report will be submitted to the Board when closure is completed. The report will demonstrate that the site has been reclaimed to background constituent levels. " In the 19 July 1999 Site Closure Soil Sampling and Chemical Analysis report. The City of Tracy stated "the lack of mobile organic components, presence of plastic liners and "cican" underlying soil show that the subsurface was not affected by the treatment facility. Therefore, ground water monitoring is unnecessary at this time and further subsurface work is not needed". However, to fulfill the requirements in Title 27, "...during the closure and post closure period, the discharger shall: continue all ground water and unsaturated zone monitoring in compliance with Section 20380...". Section 20380(e)(3) requires, "...ground water monitoring at least annually at disposal Units and at Units that will be used for five or more years for waste treatment or storage". Because the City of Tracy operated this Land Treatment Unit for a period greater than five years, and no ground water samples have been collected from beneath the facility,the City of Tracy shall conduct an investigation of the subsurface that will include both soil and ground water sampling. This investigation should be designed to assure that the requirements stated in MRP 94-216 for ground water monitoring are accomplished. Many significant tasks need to be completed at this site before the WDR and MRP for this site can be rescinded by the Board. Please submit a schedule showing tasks and due dates for fieldwork and an evaluation of closure for the site. The schedule is due 26 May 1999. Agan until the closure requirements for Land Treatment Facilities under Section 21420 Article of Title 27 have been successfully completed, the Board cannot consider"Clean Closer" for this site. — If you have any questions please call Howard Hold at-(916) 255-3379. VICTOR J. IZZO Senior Engineering Geologist HFH cc. Mr. Ed Padilla, San Joaquin County Public Health Department, Stockton Mr. John Lynch, Wright Engineering, Tracy