SITE INFORMATION AND CORRESPONDENCE

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CENTRAL VALOY REGIONAL WATER QUAY CONTROL BOARD INSPECTION REPORT 26 June 1991 DISCHARGER: Re-Manufacturing, Ltd. LOCATION & COUNTY: E. Charter Way, Stockton, San Joaquin County CONTACT(S): Stanley S. Moore INSPECTION DATE: 3 May 1991 (Annual Inspection) and 7 May 1991 INSPECTED BY: Jean McCue ACCOMPANIED BY: James Brathovde (RWQCB) , Nora Kataoka (Water Work Corp. ) , Stanley Moore (Re-Manufacturing) BACKGROUND Stanley S. Moore owns the Moore Industrial Complex and Re-Manufacturing, Ltd. , a refurbishing business located in the complex. An unlined surface impoundment (SI) has existed at the rear of the complex, next to Re-Manufacturing, since about 1970. The SI was originally built to prevent industrial discharges generated by the complex from flowing into Mormon Slough, which is north OT and directly adjacent to the SI. A variety of solvents, petroleum wastes, acids, and other industrial chemicals were discharged to the surface impoundment until at least 1981. Steam cleaning wastewater was discharged to the surface impoundment until October 1988. The SI contains hazardous levels of soluble and total lead and is being regulated under the Toxic Pits Cleanup Act (TPCA) . In 1978 a Cleanup and Abatement (C&A) Order was issued by the Regional Board to Stanley Moore for direct discharges of industrial wastes to Mormon Slough. T�- discharges violated an earlier permit adopted in September 1966. Complet- compliance with this C&A was never achieved. Fluid samples collected from the SI in February 1987, by the Department of Health Services, contained hazardous levels of lead. In January 1988, Board staff determined that the SI was subject to regulation under the TPCA. Because of Mr. Moore's failure to comply with the TPCA, a second C&A was issued by the Board in March 1989. In June 1989, a workplan to submit a Hydrogeologic Assessment Report (HAR) was finally submitted and eventually approved. Field work for the HAR began in August 1989 with the drilling of four soil borings. However, none of the borings reached ground water and no monitoring wells were installed as required by the C&A and the TPCA. Soil sampling data from the borings indicated that approximately 1 foot of soil containing hazardous levels of soluble lead still remained in the floor of the SI. During late 1989 and the first half of 1990, Mr. Moore was again given several warnings that if he did not work towards compliance with the C&A and the TPCA an Administrative Civil Liability (ACL) would be proposed to the Board. On 10 August 1990, ACL Order No. 90-236 was issued which required by specific dates: