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STATE OF CALIFORNIA GEORGE DEUKMEJIAN, Governor <br /> CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD— <br /> CENTRAL VALLEY REGION <br /> 3443 ROUTIER ROAD, SUITE A <br /> SACRAMENTO, CA 95827-3098 <br /> 31 August 1990 <br /> Dr. E.E. Wang <br /> J.M. Manufacturing Company, Inc. <br /> 1051 Sperry Road <br /> Stockton, CA 95206 <br /> SOUD WASTE ASSESSMENT TEST (SWAT) REPORT, J. M. MANUFACTURING, SAN JOAQUIN <br /> COUNTY, CASE NO. 287 <br /> We have reviewed the SWAT Report for J.M. Manufacturing Company. We have some <br /> concerns regarding the use of an assumed datum in surveying the wells. Why was <br /> the top of the concrete canal assigned an assumed elevation of 100 feet. How was <br /> this number obtained? Is there a bench mark in the area that could have been <br /> used instead of this arbitrary value? If so, why was it not used? The elevation <br /> of the water in each of the monitoring wells is included in the SWAT report. The <br /> elevations were referenced to an assumed datum and are therefore not true <br /> elevations and should not be specified. <br /> The SWAT Report is approved. However, continued investigation of the site is <br /> necessary due to the discovery of surface water contamination by asbestos. The <br /> following are comments and guidelines regarding that further investigation: <br /> 1. The SWAT report states that an investigation of the presence of asbestos <br /> in surface soils is currently underway. Please describe the measures being <br /> taken or proposed to evaluate the extent of the asbestos contamination. <br /> 2. Transportation of asbestos by wind action is described in the SWAT report <br /> as the most likely means of asbestos contamination of the site. The <br /> investigation of the presence of asbestos ion surface soils should address <br /> the possible sources of airborne asbestos. <br /> 3. The drainage canal that crosses the facility has been found to contain high <br /> levels of asbestos contamination. It appears that the drainage canal is <br /> tributary to the French Camp Slough. Has there been, or do you propose, <br /> an investigation to determine if the slough has been affected by the <br /> disposal operation? An investigation upgradient of the facility is also <br /> necessary to determine any background levels of asbestos in the area. <br /> 4. A report detailing additional site assessment work for closure of the <br /> disposal facilities was to be completed in July 1990. When will we receive <br /> this report? Will the report be in the form of a proposed closure plan? <br /> A proposal detailing the investigation and remediation, and a closure plan, which <br /> complies with Title 23, California Code of Regulations (CCR) , Division 3, Chapter <br /> 15 (formerly Subchapter 15), must be submitted to the Regional Board. These two <br /> proposals could be submitted under one cover. It is likely that closure of the <br />