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RESNA • VP'+TERWORK CORP. <br /> INDUSTRIES <br /> Mr. William H. Crooks, <br /> Executive Officer , <br /> California Regional Water Quality RECEI <br /> Control Board-Central Valley Region <br /> 3443 Routier Road, Suite A APR 18 <br /> Sacramento, California 95827-3098 ENVIRONMENTAL HEALTH <br /> PERMIT/SERVICES <br /> RE: Re-Manufacturing, Ltd. , 1825 E. Charter Way, Stockton <br /> Dear Mr. Crooks: <br /> This letter is being submitted on behalf of Mr. Stanley S. Moore, <br /> President of Re-Manufacturing, in response to the "Notice of <br /> Violation" dated 6 March 1991, for the subject facility. Mr. <br /> Moore has every intention of complying with the notice, Adminis- <br /> trative Civil Liability (ACL) Order No. 90-236 and the intent of <br /> the Toxic Pits Cleanup Act of 1984 (TPCA) . WaterWork Corporation <br /> has been retained by Re-Manufacturing to address the technical <br /> requirements of the Regional Board with regard to closure of the <br /> surface impoundment at Re-Manufacturing' s Stockton facility. <br /> Attached to the 6 March 1991 Notice were two memoranda prepared <br /> by Jean McCue, WRCE, providing comments on reports prepared by <br /> Kleinfelder and Associates entitled Soil and Ground Water Assess- <br /> ment, December 13, 1990, and Surface Impoundment Closure and Post <br /> Closure Maintenance Plan, December 14 , 1990 . As a first step <br /> toward compliance with ACL Order No. 90-236, the comments will be <br /> addressed in the order presented in the memoranda. <br /> SOIL AND GROUND WATER ASSESSMENT REPORT FOR RE-MANUFACTURING, <br /> LTD. , STOCKTON, SAN JOAQUIN COUNTY <br /> 1 . The low concentrations of methylene chloride recorded in the <br /> two soil samples collected and analyzed by the Regional <br /> Board are inconsistent with analytical results of sampling <br /> conducted by Kleinfelder. Board staff provides no conclu- <br /> sions regarding the inconsistencies . Both Board samples <br /> recorded very similar concentrations of only methylene <br /> chloride and none of the three Kleinfelder samples recorded <br /> detectable concentrations of the constituent. It is likely, <br /> therefore, that the detection is due to laboratory contami- <br /> nation/error. Future water samples will be analyzed by EPA <br /> method 601 to determine the presence of methylene chloride <br /> in water. If the constituent was actually present at the <br /> depths sampled, it would very likely be observed in ground- <br /> water. Also, future soil characterization samples and/or <br /> confirmation samples collected in the impoundment will be <br /> analyzed for 8010 constituents. <br /> 1710 MAIN STREET . ESCALON, CA 95320 • (209) 838-3507 <br /> 2350-A WALSH AVENUE • SANTA CLARA, CA 95051 • (408) 4961249 <br />