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' 2.0 BACKGROUND <br /> 2.1 Site Location and Operations <br /> ' Marina West Marine Services ("Marina West") leases property on the south levee of the Village <br /> West Marina, located on Fourteenmile Slough in Stockton, California. Marina West conducts <br /> ' boat repair and maintenance. Figure 1 shows the location of the operation on the Village West <br /> Marina. The operational area is depicted in greater detail on Figure 2. As part of their repair <br /> and maintenance work, boat hulls were sometimes pressure-washed, resulting in the deposit of <br /> ' paint chips to the surface. Boat undersides are often painted with a copper-based, anti-fouling <br /> material. The anti-fouling paint contains up to 50% cuprous oxide, an insoluble and extremely <br /> stable compound. The practice of pressure washing boat hulls has reportedly ceased. <br /> 2.2 Inspection and Sampling <br /> P P g - <br /> On July 29, 2003, San Joaquin County Environmental Health Department (EHD) personnel <br /> inspected the boat repair operation, apparently in response to a complaint. A copy of the <br /> Hazardous Waste Inspection Report is included in Appendix A. Visible paint chips on the <br /> ' surface of soil apparently prompted EHD to collect a surface soil sample ("Sample #1"). The <br /> sample was submitted to GeoAnalytical Laboratories, Inc. (ELAP No. 1157) of Modesto, <br /> California. The sample was analyzed for the "CAM-17" suite of metals using appropriate EPA <br /> Methods. The total copper concentration in the sample, 30,000 parts per million (ppm), <br /> exceeded the State of California Total Threshold Limit Concentration ("TTLC") of 2,500 ppm, <br /> ' which is characteristic of a hazardous waste. None of the other metals exceeded their respective <br /> TTLCs. However, based on total concentrations of cadmium, chromium and lead greater than <br /> 10 times their respective Soluble Threshold Limit Concentrations ("STLC"), the lab was <br /> ' instructed to analyze the sample for soluble concentrations of those metals. None of the soluble <br /> concentrations exceeded the respective STLCs. A copy of the laboratory report obtained from <br /> EHD is included in Appendix A. <br /> t2.3 Enforcement <br /> A Notice to Comply dated July 29, 2003 was issued to Marina West requiring that they cease <br /> disposal of pressure washing rinsate to the ground. A Notice to Abate dated August 25, 2003 <br /> was issued to the property owner (Pegasus Group), requiring the submittal of a workplan <br /> ' describing how remediation would be conducted, including areas to be excavated, soil disposal <br /> methods and the analytical lab to be used for cleanup confirmation. The Notice requested <br /> submittal of the workplan by September 9 and specified that EHD must approve the workplan <br /> ' before work could be conducted. The Notice indicated that the correction must be made before <br /> September 30, 2003. Copies of the Notice to Comply and Notice to Abate are included in <br /> Appendix A. <br /> t2 <br />