SITE INFORMATION AND CORRESPONDENCE_FILE 2

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Valley Motors - 2 - 21 August 2012 800 E. Main St., Stockton San Joaquin County destruction of existing TCE/PCE. The Mn04 treated water would then be pumped into monitoring wells VM-1 and VM-2, or into one or more new injection wells as a closed loop system of injection and extraction, and doing so would create a hydraulic barrier to the chlorinated solvents plume without the offsite disposal or discharge to the sewer of a conventional batch P&T system (the sewer district banned continuous treatment and discharge). A total of 300,000 gallons of water would be treated and injected over two to four months of treatment. The Report cost for full scale Recirculation P&T varied from $60,000 to $75,000 based on installation of 6 new injection wells, and treatment and reinjection of 300,000 gallons of water. The Report recommended a Recirculation P&T pilot study that would involve extracting from VM-9 and, after the above treatment, injecting into upgradient monitoring well VM-2 at a cost varying from $13,000 to $15,000. The Report also states that the above estimates include only the initial fieldwork costs and do not include operations (O&M) or monitoring costs associated with the remediation alternatives. The Report is incomplete, in that • O&M and system monitoring costs for a specific period of time are typically included with installation costs, to give an overall estimate of the cost of the remediation, and to allow a comparison of cost effectiveness between the technologies. • Also missing are figures showing the locations of the wells and the extent of the petroleum hydrocarbons plume. • The Report, while implying that the Recirculation P&T is recommended by providing costs for a pilot study of that technology, does not state why Recirculation P&T is the recommended technology, nor does it actually say that it is recommended over the other technologies. A revised Feasibility Study and Pilot Study Work Plan are due 21 September 2012. Also, State Board has issued directives concerning transfer of the UST Cleanup Fund claim from the initial claimant to their heirs. Regional Board staff have allowed considerable time delays awaiting the claim transfer with assurances of your compliance with State Board directives, and as recently as 18 July 2012, had contacted Mr. O'Neill to explain the process and was given assurances that the information would be provided forthwith to State Board. However, State Board UST Cleanup Fund staff informed me by email on 13 August 2012 that, after their repeated letters and emails to you, the required documents (death certificate, copy of the will, copy of the trust) have not been received, and that they have suspended the claim until said information is submitted. The lack of action on your part has resulted in suspension of a viable claim that can be transferred with a minimum of delay. This inaction is no longer an acceptable to delay remediation. Furthermore, compliance with Regional Board staff directives is required in order to receive reimbursement of costs incurred for monitoring, investigative, and remedial activities by the UST Cleanup Fund (Fund). Therefore, a formal Cleanup and Abatement Order (CAO), pursuant to Section 13304 of the California Water Code, is currently being prepared for review by UST Program management. Upon approval and issuance, should