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Mr. James Diel -4- 18 February 2011 <br /> Former Tracy Maintenance Facility <br /> with the underlying groundwater, it remains a persistent source of petroleum <br /> constituents to groundwater. Although plume stability is preferable to plume <br /> migration, stability itself is not an acceptable endpoint if a continuing source of <br /> groundwater pollution remains. <br /> 11. The low-risk site closure evaluation presented in Section 6 follows interim <br /> guidance for fuel sites in California Regional Water Quality Control Board Region <br /> 2. Although the framework of six evaluation criteria presents a structure in which <br /> to summarize the findings of the LNAPL investigation, Region 5 staff does not <br /> evaluate non-UST cases for closure in this manner. The site will not be a <br /> candidate for closure until UP has demonstrated that; 1) it has removed LNAPL, <br /> using appropriate methods, to the extent practicable; 2) a Land Use Covenant is <br /> in place to prohibit the use of shallow groundwater; and 3) groundwater TPHd <br /> concentrations are decreasing and will reach background in a reasonable time. <br /> Please respond to these comments in letter form by 18 March 2011. We will work with <br /> UP to evaluate corrective actions and schedule submittal of a Corrective Action Plan in <br /> early 2011. <br /> If you have any questions regarding this matter, please contact me at (916) 464-1588, <br /> or by email at kdominic@waterboards.ca.gov. <br /> KATHRYN L. DOMINIC, P.G. <br /> ENGINEERING GEOLOGIST <br /> cc: Mr. Michael Infurna, San Joaquin County Department of Public Health, Stockton <br /> Mr. James Eisert, ARCADIS, Roseville <br />