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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 <br /> SACRAMENTO,CA 95827-3098 - - OCT <br /> i �j 199 <br /> ENVIRONMENTAL HEALTH <br /> PERMIT/ScRVICES <br /> 17 October 1989 <br /> Mr. Ed Reiche <br /> Gold Bond Building Products <br /> 800 West Church Street <br /> Stockton, CA 95203 <br /> GOLD BOND SITE, 800 WEST CHURCH STREET, STOCKTON, AENC'S RESPO!:SE TO OUR <br /> 29 AUGUST 1989 CORRESPONDENCE <br /> We have reviewed the American Environmental Management Corp. 's, 26 September <br /> 1989 response to our 29 August 1989 correspondence regarding your request for <br /> a site-specific variance. In our letter we informed you that, based on the <br /> information provided, your variance application could not be considered at <br /> that time. Your consultant has responded to our comments by providing a new <br /> interpretation of the site hydrogeology, and revising the boring logs for the <br /> existing wells. <br /> The goal of the tank monitoring program is to detect leaks before ground water <br /> becomes contaminated. The regulations prescribe a number of monitoring <br /> alternatives one of which is required for adequate leak detection. A site- <br /> specific variance may be granted if an applicant demonstrates by clear and <br /> convincing evidence that an alternative monitoring program is capable of <br /> detecting any release which may occur. <br /> Based on the information available, vadose zone monitoring is not feasible for <br /> this site. Therefore, an appropriately designed ground water monitoring <br /> system seems to be the only reasonable alternative. However, we do not <br /> believe the existing wells are adequate for this monitoring system because <br /> they are not designed to detect floating product. In addition, if the wells <br /> are screened below an impermeable zone, as the report indicates, it is not <br /> clear how they would be able to detect any release from the tank. <br /> The original boring logs submitted with the 3 March 1989 hydrogeologic <br /> assessment report indicated that saturated conditions were encountered above <br /> the zone where the wells were screened. Based on this discrepancy, Regional <br /> Board staff concluded that the actual elevation of the uppermost saturated <br /> zone had been misinterpreted. <br /> The revised boring logs submitted with the 26 September 1989 report indicate <br /> that saturated conditions were first encountered in a deeper zone. However, <br /> because this zone was logged from auger cuttings, there is some degree of <br /> uncertainty in this determination. <br /> According to the 26 September 1989 report, the uppermost saturated zone at <br /> this site is confined and exists at a proven depth of over 25 feet, and the <br />