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• MEMORANDUM` <br /> CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD - CENTRAL VALLEY REGION <br /> 3443 Routier Road, Suite A Phone: (916) 361-5600 <br /> Sacramento, CA 95827-3098 ATSS Phone: 8-495-5600 <br /> TO: GREG VAUGHN P « k OM: JEAN McCUE <br /> Senior Engineer * Water Resource Control Engineer <br /> J U L 12 1991 <br /> DATE: 26 June 1991 ENVIRONMENTA! HEALWGNATURE: <br /> PERN;IT/SAN'✓;Cc <br /> SUBJECT: CLOSURE PLAN AND HYDROGEOLOGIC ASSESSMENT REPORT REVIEW FOR RE-MANUFACTURING, <br /> LTD. , STOCKTON, SAN JOAQUIN COUNTY <br /> On 14 December 1990, Kleinfelder submitted two reports on behalf of Mr. Stanley Moore <br /> of Re-Manufacturing Ltd. entitled, "Soil and Ground Water Assessment" and "Closure Plan <br /> for Re-Manufacturing Surface Impoundment" . The reports were submitted in an attempt <br /> to satisfy two requirements of Administrative Civil Liability (ACL) Order No. 90-236. <br /> The ACL required Mr. Moore to submit a HAR and closure plan for the TPCA surface <br /> impoundment at his facility by 15 December 1990 and implement the closure plan by <br /> 1 June 1991 . Upon review, staff found that the HAR was still incomplete and the <br /> closure plan could not be approved. Therefore, on 6 March 1991 the Executive Officer <br /> issued a Notice of Violation (NOV) of the ACL to Mr. Moore. <br /> The NOV required that the remaining information to complete the HAR be submitted and <br /> an approvable closure plan be submitted and implemented by 1 June 1991, in order to <br /> avoid paying the balance of the original civil liability. Enclosed with the NOV were <br /> two memorandums with staff's comments on the two December 1990 Kleinfelder reports. <br /> In response to the NOV, we received a letter from Water Work Corp. by FAX on <br /> 16 April 1991 , on behalf of Mr. Moore. In the letter, Water Work Corp. responded to <br /> our comments in the two memorandums. An official copy of the Water Work's letter was <br /> received on 17 April 1991 . <br /> On 31 May 1991, we received a plan entitled "Addendum to Surface Impoundment Closure <br /> and Post Closure Maintenance Plan" and a FAXed copy of a report entitled "Addendum to <br /> Soil and Groundwater Assessment Report (Hydrogeologic Assessment Report)" (HAR <br /> Addendum) . The reports were again submitted by Water Work Corp. , on behalf of Mr. <br /> Moore. <br /> CLOSURE PLAN REVIEW <br /> The closure plan does not contain sufficient detail to be implemented or approved as <br /> submitted and more information is required. Following are general comments on the <br /> plan: <br /> Water Work Corp. used a statistical evaluation to establish a "background threshold <br /> limit value" (BTLV) of 785.7 mg/kg. The data used in the analysis was from Mormon <br /> Slough samples collected in April and May 1991 . However, our evaluation of the data <br /> indicates that the slough has been impacted either by the surface impoundment or by <br /> drainage from past disposal practices emanating from the discharger's property. Also, <br /> in 1978 a previous Cleanup and Abatement Order was issued because wastes were <br /> discharged directly into the slough. Therefore, staff does not agree that the high <br />