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STATE OF CALIFORNIA-Environmental Prot Agency } <br /> . 11 'i -U, PETE WILSON,Governor <br /> CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD <br /> CENTRACVALLEY REGION f�h '► ���,�,��'.�}r��r E�i_3'�l iOF <br /> 3443 Routier Road,Suite A } i <br /> ZC <br /> Sacramento,CA 95827-3098 <br /> PHONE:(916)255-3094 <br /> FAX:(916)2555-30155 9-0 NOV 2T <br /> s: <br /> 26 November 1996 � <br /> Ms.Margaret Lagorio <br /> San Joaquin County Environmental Health Division <br /> 344 E..Weber Avenue,Third Fluor . <br /> Stockton,CA 95241-4388 <br /> 3i- <br /> NONCONCURRENCE WITH SAN JOA UIN COUNTY'S NO*I2�ACTION REQUIRED <br />•" -DETER11MNATTQN; 0GO"S(FORMER TEXACO),LODI,-SA(N-J0AQU1N-COON-T- -Y-- . . .r <br /> On 24 October 1996,San Joaquin County's Technical,Review Committee voted to issue a no further action <br /> required Ietter for the Togo's(formerly Texaco)site,and to issue permits,upon request of responsible party, <br /> for the destruction ofmonitoring wells. Regional Board staff voted against closure of this site. This <br /> disagreement was due,in part,to the incomplete investigation of volatile organic compounds(VOCs), <br /> particularly 1,2-13CA, in sails beneath theformertank pit above the groundwater contamination. The existing <br /> VOCs and petroleum hydrocarbons in the contaminated groundwater are commingled from off`and on-site: <br /> sources. <br /> 1 <br /> Staff'discussed the problem with.Mr.Michael Brady,attorney for the;City of Lodi. We understand there are <br /> several potential responsible parties for this site,all ofwhom-are involved in negotiating cleanup responsibility: <br /> Also,participants in the City ofT odi's.chlorinated solvent plume negotiations,would all be adversely affected <br /> y San 3tsaquin County Environmental I3ealth Division°s actions to proceed with administrative closure for the <br /> Togo's site. Our position is that the Togo's site may have contributed to the existing commingled VOC plume , <br /> and should not`be issued a no ftirt'her action required document. t <br />.z The Department of Toxic Substances Control(DISC),the City of Lodi,and Regional Board staff requested that 1 <br /> the San Joaquin County Environmental Health Division,;as lead agene ,not issue;a no further action required <br /> letter until the source of VOCs and MTBE in the commingled groundwater plume existing beneath the site has <br /> been fully investigated and remediated. 1,2-DCA,is a component in gasoline. Enclosed-is a staff memorandum <br /> -��-wllicYt recommends documentation:that;1,2-DCA.and.,V.00s are.not.pr sen#.in_over to so ls.and`-a continuing <br /> source contaminating groundwater,prior to issuing a no further action-required letter. These recommendations <br /> are in agreement with DTSC and the City of Lodi's requests to remediate the MTBE and VOCs in groundwater <br /> beneath this site. i <br /> The City of Lodi relies exclusively can groundwater fax municipal watelr supply. If`tlte eisting monitoring wells <br /> are destroyed,replacement monitoring.wells at similar locations would be required to be installed.to continue the <br /> groundwa,t .:in`vest gation ofthe Y fI and chlorinated solvent plum .We disagree with the de�ction of the. <br /> existing monitoring wells until an agreement is in place to continue th�ir use for groundwater monitoring. <br /> Ifyota have any questions,please call James Brathovde at(916)255-3131 <br /> In Executive Officer <br /> V ll <br /> Eiiclosures ., i <br /> ;a: <br />