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i <br /> E' f OV (:AL{F0k K',fs _ OEQROC DCUKAAFJ1AN,QOrarnor <br /> CALIFORNIA REGIONAL,. WATER QUALITY CONTROL BOARD— <br /> CENTRAL VALLEY REGION <br /> 3443 ROUnER ROAD <br /> SACRAMENTo,CA 96827-30H <br /> 23 October 1987 <br /> Mr. Michael Bennett <br /> Environmental Coordinator <br /> Pacific Gas and Electric <br /> 1401 Fulton Street <br /> Fresno, CA 93760 <br /> TRACY SERVICE CENTER REPORT AND PROPOSAL, SAN JOAQUIN COUNTY <br /> We have received and reviewed the subject proposal and report accompanying your <br /> letter of 29 September 1987, Enclosed is a memorandum regarding the proposal . <br /> Two primary issues were raised in your 29 September letter: identification of a <br /> 1 "lead" agency and the need or timing for tank removal . <br /> The unaerground tank regulations (Title 23, California Administrative Code) <br /> clearly indicate that the local county authority, in this case the San Joaq On <br /> Loc,, Health District, has primary responsibility for implementing the underground <br /> Lank program, but do not prevent the Regional Boards from taking independent <br /> actions to protect water quality. The regulations also clearly state that the <br /> local authority may request technical support from the Regional Boards for water <br /> quality issues involving underground tanks. Accordingly, the San Joaquin Local <br /> Health District is, and will remain, the "lead" agency for underground tank issues <br /> at the site and the Regional Board will continue to supply technical support, The <br /> Regional Board will not, however, refrain from taking independent enforcement <br /> action if necessary. <br /> Regarding tank removal , our comments of 16 June and 22 September requested that PG <br /> and E address both tank removal and mitigation of Soil contamination. In our <br /> discussions with the Local Health District, they expressed the desire PGandE <br /> remove the tank and define or remediate contaminated soil at the same time. In <br /> the latest workplan, PG and E proposes to remove the tank, collect soil samples <br /> immediately below the tank, and backfill the excavation. Considering contamina- <br /> tion has already reached ground water this proposal in insufficient. Contaminated <br /> soils should be defined and mitigated as soon as possible, preferably at the same <br /> time as tank removal , to prevent further ground water contamination, <br /> Permits for the proposed work should be obtained through the Loc "I Health <br /> District, Please contact our office at least 24-hours in advance of lrltiating <br /> work on-site. <br /> If you have any questions regarding Lhof a:r,ve or the enclosed, please contact me <br /> at (916) 361-5742. <br /> GARY A. REENTS, P.E. <br /> Project Engineer <br /> GAR:ej <br /> Enclosure <br />