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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 FROM: JEAN McCUE <br /> Senior Engineer Water Resource Control Engineer <br /> TPCA Unit TPCA Unit <br /> DATE: 19 February 1991 SIGNATURE: t a,. . C_ <br /> SUBJECT: SOIL AND GROUND MATER ASSESSMENT REPORT FOR RE-MANUFACTURING, LTD., STOCKTON, <br /> SAN JOAQUIN COUNTY <br /> On 30 November 1989 William J. Hunter and Associates submitted a report entitled "Work <br /> Plan Status Report and Proposed Pit Closure", on behalf of Mr. Stanley Moore of Re- <br /> Manufacturing, Ltd. . It contained information which was intended to complete the <br /> Hydrogeological Assessment Report (HAR) requirement of the Toxic Pits Cleanup Act <br /> (TPCA) . Marie McCrink's 8 February 1990 memorandum discussed deficiencies in the <br /> report and a 26 March 1990 memorandum listed minimum recommended tasks toward <br /> completion of the HAR. This included a COMPLETE definition of the lateral and vertical <br /> extent of soil contamination, an evaluation of whether or not ground water has been <br /> impacted, and if impacted, to what extent. <br /> On 10 August 1990, the Board adopted Administrative Civil Liability (ACL) Order No. 90- <br /> 236, against Mr. Moore and Re-Manufacturing, Ltd. . The ACL included requirements that <br /> a complete HAR and Closure Plan be submitted by 15 December 1990. Following adoption <br /> of the Order, Mr. Moore's new consultants, Kleinfelder, conducted additional <br /> investigations at the facility. Kleinfelder submitted two reports on 14 December 1990 <br /> on Mr. Moore's behalf: a "Soil and Ground Water Assessment" (SGWA) report and a <br /> "Surface Impoundment Closure Plan" . The SGWA contains information relating to the <br /> completion of the HAR, which is required by the ACL as well as the TPCA. The closure <br /> plan also contains some additional information relating to the HAR. Although <br /> significant progress has been made, most importantly the installation of three <br /> monitoring wells, the HAR remains incomplete and lacks sufficient information to <br /> complete a closure plan. <br /> Following are comments on the SGWA, as well as the status of the HAR. (The Closure <br /> Plan will be discussed in a separate memorandum.) Kleinfelder's report satisfied some <br /> of the recommended tasks listed in the 26 March 1989 memorandum. However, additional <br /> recommended tasks which relate to water quality must still be satisfied in order to <br /> complete the HAR. I have reiterated Ms. McCrink's comments in italics and will discuss <br /> to what extent this recent investigation complies with the specific requirements of a <br /> HAR: <br /> 1 . Drill, construct, and develop three ground water monitoring wells. Federal and/or <br /> State approved standards for the completion of ground water monitoring wells must <br /> be followed. Some of these details were described in the 13 June 1989 letter which <br /> contained comments on your 30 May 1989 work plan. A monitoring well location and <br /> construction plan must be submitted and approved by the Regional Board prior to <br /> drilling. <br /> Three 2-inch diameter monitoring wells (MW-1, 2, and 3) with 20-foot screens were <br /> installed at the facility in September 1990. Well construction details and boring <br />