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F <br /> . , ; p_ GEORGE DEUKMEJIAN,Governor <br /> CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD-- <br />} CENTRAL VALLEY REGION <br /> 34.. 3 ROUTIER ROAD <br /> SACRAMENTO,CA 85$27-3098 <br /> 4 April 1988 <br /> E�VIRRMp'�ER���+ES c <br /> Mr, Michael Hansen FE <br /> Kayo Oil Company <br /> P.O. Box 190 <br /> Lodi, CA 95241 <br /> PROBLEM ASSESSMENT REPOR'T'S (PAR) iOR�_ <_EAST .-HIGHWAY 127IN LODI <br /> AND EAST 4325- WASHINGTON STREET Iii STOCKTON <br /> Thank you ,for submitting the- two PARS prepared by Groundwater .. <br /> Bioremediation services (a Du Pont subsidiary) . The reports, <br /> nearly duplicates of each other, were submitted together and have <br /> basically the,. same problems; i.e. , the following information was <br /> not included <br /> Results and data from the Step-Drawdown Test conducted at <br /> each site. <br /> Raw data sheets for the recent ground water analyses. <br /> The proper signatures of certification and registration are <br /> lacking. California law requires that "public" reports <br /> containing geologic and/or engineering information be signed ' <br /> by a properly certified or registered individual. Reports <br /> sent to any Regional Board or other regulating agency are <br /> "public". <br /> Both reports . have other areas which require further evaluation <br /> and clarification: <br /> -- The reports, and subsequent phone conversations, indicate <br /> that the constant rate pumping tests (CRPT) at .each site - <br /> were performed at rates based on Step-Drawdown data (which <br /> were not in the reports) . The CRPT were each designed to <br /> run for 24 hours but had to b curtailed after 12 hours at <br /> 4325 Washington Street and 18 hours at 800 East Highway 12 <br /> due to aquifer dewatering. Your consultant for the tests <br /> completed a Cooper-Jacobs analysis of the pumping test data <br /> even though most assumptions for use of this analytical <br /> method were not met. Also, the units of transmissivity are <br /> inconsistent in the reports (gpd/ft versus gpf/d) . <br /> - At each site the benzene plum of contamination has been <br /> adequately defined; however, the total petroleum hydrocarbon <br /> (TPH) plume has not. The extent of TPH contamination at <br /> I both sites has not been determined nor has any explanation <br /> �-"''-- <br />