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California Regi Control nal Water Quality Board <br /> vCentral Valley Region 109,I <br /> Robert Schneider,Chair <br /> Terry Tamminen Arnold Schwarzene er <br /> Secretary for Sacramento Main Office g!; <br /> Governor <br /> Environmental Internet Address: http://wwwswrcb.ca.gov/rwgcb5 <br /> Protection 11020 Sun Center Drive#200 Rancho Cordova,CA 95670-6114 <br /> Phone(916)464-3291 nn ��QQ /j <br /> 18 June 2004 W��((LSII V �D <br /> Mr. Bob Hopkins Mr. Jay Allen JUN 2 12004 <br /> Union Oil Company of California Stone Brothers Management Company ENVIRONMENT HEALTH <br /> 276 Tank Farm Road. 1024 W. Robinhood Dr. <br /> P.O. Box 1069 Stockton, CA 95207 PERMIT/SERVICES <br /> San Luis Obispo, CA 93406 <br /> NOTICE OF VIOLATION, CLEANUP AND ABATEMENT ORDER (CAO)NO. 5-00-707,FORMER <br /> UNOCAL STATION #5098 AT 5606 PACIFIC AVENUE,AND FORMER MONTGOMERY WARDS AUTO <br /> SERVICE AT 5400 PACIFICA VENUE, STOC%TON,SANJOAQUIN COUNTY, <br /> We reviewed the 15 June 2004 Work Plan and Schedule to Cease Plume Movement and Define Plume Limits <br /> within the B-Zone(Workplan),required by CAO No. 5-00-707, submitted by ENSR International(ENSR)on <br /> behalf of Unocal. The Workplan recommends the following actions: <br /> • Rehabilitate and restart the Soil Vapor Extraction(SVE) system by I August 2004 to "...provide 'pull" <br /> on groundwater and control plume spread. " <br /> • Modify and restart the Air Sparging(AS) system by 1 August 2004. <br /> • Complete an evaluation of In-Situ Chemical Oxidation (ISCO)by 15 September 2004,for ozone, <br /> Fenton's reagent,hydrogen peroxide,or nutrients. <br /> • If needed, install new monitoring wells MW-27, -28, -29, and-30 by 15 October 2004 <br /> The Workplan does not comply with the requirements of CAO No. 5-00-707, Order No. 15, which states "...work <br /> to begin within 30 days of a report submittal, to define the new plume limits and cease plume movement." You <br /> are hereby directed to install the proposed monitoring wells by 15 July 2004 and provide a Report, which defines <br /> the extent of the new plume by 1 August 2004. We do not agree that hydraulic control of the groundwater plume <br /> will be achieved with AS and SVE alone. Therefore, the above-mentioned Report shall also include a summary <br /> of efforts taken to cease plume movement and the results of those efforts. <br /> Continued failure to comply with CAO No. 5-00-707 may result in Administrative Civil Liability(ACL) fines up <br /> to $1,000.00 per day [Water Code Section 13350(e)(1)(13)]retroactive to the original schedule of the Order, <br /> and/or loss of Cleanup Fund eligibility. Also note that we require submittal of site-specific bench scales studies <br /> for all ISCO injections,to provide a basis for determining what Waste Discharge Requirements may be required <br /> for that specific ISCO technology. You may call me at(916)464-4615 for questions or additional information. <br /> /� <br /> AMES L.BARYON,R.G. <br /> Engineering Geologist <br /> cc: Mr.Mark Owens,UST Cleanup Fund, SWRCB, Sacramento <br /> Mr.Mike Infurna, San Joaquin County Environmental Health Division, Stockton <br /> Ms. Jill Tracy, Esq., UNOCAL,Brea <br /> Mr. Ben Henningburg, ENSR International, Sacramento <br /> California Environmental Protection Agency <br /> Co Recycled Paper <br />