Laserfiche WebLink
r � <br />f <br />�rI <br />3300 Waterloo <br />Page 2 <br />N4 <br />The report did not specify that the recommendations were in conformity with the California <br />Code of Regulations, Title 23, Division 3, Chapter 15, Article 11 which outlines the <br />requirements of corrective action. It was determined by PHS/EHD (lead regulatory agency <br />to provide oversight for the investigation and clean-up of contamination resulting from <br />leaking underground storage tanks in San Joaquin County) that conditions were present to <br />require soil and groundwater investigation to determine a cost-effective method of cleanup. <br />The report failed to provide adequate assessment of the potential effects that residual <br />contamination may have on groundwater and a feasibility study to evaluate alternatives for <br />remediation of the actual or potential adverse effects of the unauthorized release. Based <br />on evidenced contamination, a potential threat to groundwater exists. <br />The report included as basis for closure the statement that "Reports previously prepared for <br />this site and this report indicate that neither "contamination," "pollution", nor "nuisance" exist <br />at this site." This statement failed to consider that under definitions within Division 7 of <br />the Clean Water Act, "pollution" may include "contamination" which includes any equivalent <br />effect resulting from the disposal of waste, whether or not the waters of the state are <br />affected. Also "nuisance" has been demonstrated during tank removal along with the <br />subsequent excavation. Significant contamination in the form of petroleum hydrocarbon <br />pollution continues to act as a nuisance to the people of San Joaquin County. <br />Please note that PHS/EHD operates under the requirements of a contract with the State <br />Water Resources Control Board in which authorization is granted to require the <br />investigation and cleanup of contamination, pollution, and nuisance relating to an <br />unauthorized release from underground fuel storage tanks. <br />In regards to the content of the report in relation to conformity with recommendations from <br />the Tri -Regional Guidelines Appendix B for closure reporting, the report failed to provide <br />all the technical information requested to evaluate the site for closure. Please submit all <br />information necessary for the evaluation of the site for closure by March 31, 1995. If you <br />have any questions regarding the report's deficiencies, please do not hesitate to contact Mary <br />Meays at (209) 458-0337. <br />Donna Heran, Director, REHS <br />Environmental Health Division <br />/V[ <br />Mary Meays, Senior REHS <br />Site Mitigation Unit <br />cc: Elizabeth Thayer, CVRWQCB (w/enclosure) <br />cc: .lames Giannopoulos, SWRCB (w/enclosure) <br />cc: Lori Casias, SWRCB (w/enclosure) <br />Jane. + i son, REHS <br />Supervisor <br />