SITE INFORMATION AND CORRESPONDENCE_FILE 2

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Page 1 of 2 Vicki McCartney [EH] From: Nuel Henderson [EH] Sent: Monday, September 24, 2012 10:26 AM To: 'BTROMMER@waterboards.ca.gov' Cc: 'Kirk Larson';Adrienne Ellsaesser[EH]; Harlin Knoll [EH]; Vicki McCartney [EH]; Lisa Medina [EH] Subject: Sites CUF Recommended for Closure and LTCP Review Attachments: Brief August12 Five-Year Recommended Closures A.xlsx Bob, During the recent training on applying the LTCP to our cases I inquired as to what should be done about cases your agency was going to review for the LTCP that were already in the closure process; I was told to contact you regarding the status of such sites and that the closure process would continue as is. Attached is the list of San Joaquin County LOP sites taken from the list your agency provided to the subordinate agencies. This modified list provides a note on the current closure status of each site. There are 31 sites in the LOP of San Joaquin County on the list. The 31 sites State Board will review can be characterized as follows: 14 are in the final stages of closure where closure notifications have been sent or there are issues that primarily revolve around well destruction or receiving documents such as RTOs or waste disposal certification (CUF Nos. 367, 380, 757, 1026, 2429, 4423, 5036, 8753, 10934, 11515, 14125, 14558, 17179, and 17905). 8 Sites are starting the closure process with preparation of closure reports directed or with closure reports in review(CUF Nos. 1651, 1878, 2965, 5820, 10841, 14167, 15783, and 16475). 5 Sites have simple issues discussed with Kirk Larson that we hope can be resolved prior to closure, such as domestic well testing, soil gas results resolution, etc. (CUF Nos. 889, 4954, 7709, 8590 and 17509) 2 Sites have been closed (CUF Nos 678 and 12228). 1 Site was recommended for closure but approved for remediation (CUF No. 8109) and needs resolution. 1 Site was recommended for remediation, not closure; remediation is pending (CUF No. 14349). A total of 29 sites are moving toward closure or have been closed; one site probably is also moving toward closure, the last site was not recommended for closure and is not moving toward closure. -,10 One of the sites with issues discussed with Kirk Larson (CUF No. 7709), Marci's Diesel at E. Loomis Road in Stockton poses a concern to our agency in that a very large residual mass of diesel (approx. 107,000 pounds) that has not been remediated and a rising groundwater elevation that currently has groundwater at the base of a sand unit interpreted by both the consultant and our agency as a channel sand. This site is in an area of high groundwater usage. If groundwater continues to rise, the suspected channel sand may become a conduit for lateral migration of diesel-impacted groundwater, which will not be detected without continued monitoring of the plume. Concern with this site is shared by our Director. Admittedly, this is a difficult site for remediation and an effective technique has not yet been identified, but in the opinion of our agency, it would be prudent to make additional effort, especially in the sand unit and the uppermost portion of the fine-grained unit underlying the sand, to accelerate the rate of mass reduction, possibly though ISCO. Any success achieved there should reduce the risk posed by the large contaminant mass when the site is closed an not being monitored. (Note: the consultant recently reduced the estimated contaminant mass to 3,300 pounds through use of a geometric mean for determining an average concentration for the mass calculation. No technical justification for utilizing a geometric mean instead of an arithmetic mean was provided. A discussion of the geometric mean in Wikipedia does not appear to justify the use of the geometric mean in this case. The EHD considers the larger mass estimate to be closer to the mark.). Your consideration and input on this case would be appreciated. 9/27/2012