SITE INFORMATION AND CORRESPONDENCE

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t 5708 Hwy 99, Stockton Page 2 Rather than require a subsurface investigation, involving collection of soil samples from beneath the septic tank and leach lines for analysis, the owner was given the option of sampling the on- site well for the chemicals found in the septic tank,provided that the environmental consulting firm signing the closure report agreed with this investigation alternative. The owner was directed to have a work plan submitted to the EHD confirming the chosen alternative. In addition, the owner was directed to have the septic tank pumped out with sufficient notice to EHD staff to allow inspection of the empty tank for cracks or leaks. The contents of the septic tank were to be disposed of properly. In your letter of December 4, 2004, you stated that pumping and disposal of the septic tank contents had been completed. This was the first notification received by the EHD that the tank had been pumped. Since the EHD was not notified, inspection of the tank for cracks and leaks did not occur. The name of the facility receiving the contents of the septic tank was not provided. Confirmation from the facility that received the material must be provided along with an acknowledgement that they were aware that the load contained chemically contaminated waste. It is unfortunate that the Saint Francis Motel owner failed to notify the EHD prior to the first sampling of the well and the pumping the septic tank so that these activities could be documented and observed by EHD staff, as required by UIC investigation protocol. The EHD will provide further written notification to the motel owner regarding the current status of his property with respect to the UIC program. The EHD has had previous conversations with you regarding the UIC program, and you were referred to our contact at the United States Environmental Protection Agency(USEPA), Elizabeth Janes, for additional information on the program. On December 24, 2002, Ms. Janes sent you electronic mail regarding UIC regulations and drinking water standards. She explained that the UIC regulations were promulgated pursuant to the United States Safe Drinking Water Act to prohibit the use of subsurface disposal systems, including septic systems, for the disposal of substances that may contaminate underground sources of drinking water. She further explained that each site had to be evaluated against a list of factors that included depth to water, travel time to the drinking water aquifer, the volume of contaminants discharged, and the length of time involved. The EHD is concerned that chemicals were discharged into a septic system that disposes into the subsurface without treatment. It is unknown when the disposal started so the volume, concentration and total time of chemical disposal is unknown. The sample from the septic tank was not collected until 13 days after the discovery of the drug lab. During this period, sewage from the other motel rooms continued to be disposed to the septic system. Therefore, the fact that any chemicals at all were found in the septic tank indicates that a significant amount of chemicals may have been previously discharged into the septic system. These chemicals may now be in the soil surrounding the septic tank as well as in the subsurface disposal area (leach