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California Regional Water Quality Control Board 11 Central Valley Region � d Robert Schneider,Chair Winston H.Hickox : 36 Gray eD avis Secretary for Sacramento Main Office Environmental Internet Address: httpJ/v .sw b.ca.gov/mgcb5 Protection 3443 Routier Road,Suite A,Sacramento,California 95827-3003 phone(916)255-3000•FAX(916)255-3015 29 October 2003 Mr. Dale Gillespie Geweke Land Development and Marketing PO Box 1210 Lodi, CA 95241 NOTICE OF VIOLATION(NOV), CLEANUP AND ABATEMENT ORDER(CAO)NO. 93-701, GEWEKE PROPERTY, 16 SOUTH CHEROKEE LANE,LODI,SAN JOAQUIN COUNTY I reviewed the Quarterly Report- Third Quarter 2003 (Report), CAO No. 93-701 submitted on 24 October 2003 for Geweke Land Development and Marketing by Advanced GeoEnvironmental Inc. (AGE). The Report states 1,2-dichloroethane (1,2-DCA)was detected in groundwater at a concentration of 22 gg/L in MW-16, the offsite downgradient monitoring well. 1,2-DCA has been consistently detected in MW-16 since December 2002. AGE has recommended in each quarterly report since December 2002 that a new well to define the lateral extent of the 1,2-DCA is not currently necessary. 1)CAO No. 93-701 Requirement 31 states "Maintain a sufficient number of monitoring wells to completely define and encompass the contaminant plume(s) (lines of zero contamination in all water bearing zones). If groundwater sampling results indicate that contamination has migrated to or past any of the outermost or deepest monitoring wells, the Dischargers shall resample the following month. If contamination is confirmed, the Dischargers shall submit within 30 days of receiving the sample results, a work plan for installing additional monitoring wells. The additional monitoring wells shall be installed and sampled within 60 days of submitting the workplan (or longer as approved by the Executive Off cer)." Quarterly groundwater monitoring of downgradient offsite monitoring well MW-16 shows consistent detections of 1,2-dichloroethane (1,2-DCA) over the last four quarters of groundwater monitoring. Additional lateral characterization of the 1,2-DCA groundwater plume is required by CAO No. 93-701. Groundwater analysis for perimeter monitoring wells MW-7 and MW-11 also reported 1,2-DCA. I have not received the required workplan to install additional monitoring wells to re- establish the lines of zero contamination. I will not recommend enforcement action if a workplan is received by 30 November 2003. Until then, this letter will serve as your NOV regarding this matter. If you fail to complete the required work, any fines (civil liabilities)will be based on the dates listed in CAO No. 93-701. 2)The Report recommends implementation of a six month pilot study using ozone injection in the source area, around the dispensers and MW-14. While I generally concur with the proposal for a pilot study,I feel that a bench scale test,using site groundwater and soil,needs to precede the pilot study,in order to identify any conditions that might render the pilot study ineffective. For instance,iron fouling of the injection system due to reactions between the site groundwater and soil may result in total shutdown of the ozone system. A bench scale test could identify problems and help determine the feasibility of the proposed remediation,prior to spending more funding for a system that may prove problematic. I recommend that a pilot study workplan include a bench scale test to determine if ozone injection is feasible for this site. If ozone proves to be problematic,then an California Environmental Protection Agency 0 Recycled Paper The energy challenge facing California is real. Every Californian needs to take immediate action to reduce energy consumption. For a list of simple vrays you can reduce demand and cut your energy costs,see our Web-site at http://w .sw b.ca.gov/mgcb5