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Mr. Ken Gillies <br /> Gillies Trucking <br /> 3931 Newton Road, Stockton <br /> Page 3 of 3 <br /> 2007. These results do not appear to represent a consistent downward concentration <br /> trend that supports the leaching model. <br /> The EHD also notes that two of the new easternmost wells, initially non-detect for <br /> TPH-d, had detectable concentration of TPH-d during the last quarterly monitoring event <br /> in March 2007. It therefore appears possible that the dissolved plume of TPH-d extends <br /> further toward the east than was evident when the 4"' QR '06 was prepared. The EHD <br /> usually requires four quarters of monitoring of new wells before making a decision in <br /> favor of site closure based on or in part on the monitoring results. For that reason and <br /> the issues noted above, the EHD does not concur with the closure request conveyed in <br /> the 4h QR '07. <br /> This decision is subject to appeal to the State Water Resources Control Board (SWRCB) <br /> pursuant to Section 25296.40(a)(1) of the Health and Safety Code (Thompson-Richter <br /> Underground Storage Tank Reform Act-Senate Bill 562). Please contact the SWRCB <br /> Underground Storage Tank Program at (916) 341-5752 for information regarding the <br /> appeal process. <br /> The EHD has discussed your closure request with the Central Valley Regional Water <br /> Quality Control Board (CVRWQCB). The CVRWQCB reviewed the 4`h QR '06 and <br /> informed the EHD that they do not consider your site to fit the requirements for a low risk <br /> closure. The CVRWQCB believes that remediation of your site is required and that <br /> natural attenuation is not a suitable remedial method for your site. The EHD will meet <br /> with the CVRWQCB in July and discuss your site and possible options. The EHD and <br /> CVRWQCB will meet with you and your consultant to discuss potential alternatives with <br /> you should you request such a meeting. After meeting with the CVRWQCB, and with <br /> you should you wish, the EHD will issue a directive letter for your site. Continue to <br /> implement the currently approved groundwater monitoring program for your site. <br /> Questions or comments may be directed to Nuel Henderson by mail (address on letter <br /> head), or by telephone at (209) 468-3436. <br /> Donna Heran, REHS, Director <br /> Environmental HealthDivision <br /> Nuel C. Henderson, Jr., PG Margao, RE S <br /> Engineering Geologist Program Coordinator <br /> Unit IV- Site Mitigation Unit IV— Site Mitigation <br /> cc: James L.L. Barton— CVRWQCB <br /> Victor Cherven — UEC <br /> Clyde Hebbron - UEC <br />