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Remo Canepa Page 4 of 4 <br /> 6230 Pacific Avenue March 5, 2012 <br /> Stockton , CA <br /> • The EHD is not aware of any observation of free product in any of the site wells , which <br /> would help maintain high dissolved concentrations despite natural attenuation and active <br /> remediation . At the request of the EHD , AGE has also reviewed records and verbally <br /> confirmed a lack of references to free product in site monitoring wells. <br /> • AGE estimates that 75 pounds of dissolved MTBE currently impact groundwater on the <br /> site , which AGE believes is an underestimation as the down-gradient extent of impacted <br /> groundwater has not been delineated . <br /> The totality of various AGE and EHD observations leads the EHD to consider that it is more <br /> probable that a second , post- 1993 release has occurred from the current UST system than that <br /> a second release did not occur; therefore the EHD will issue the requested Unauthorized <br />:I <br /> Release ( UAR) and file the proper notifications . <br /> As noted in the EHD letter of 18 May 2011 , there is no record of a groundwater monitoring event <br /> being conducted on your site since May 2010 , you have been and are currently under directive <br /> to conduct semi-annual monitoring . You are directed to reinitiate groundwater monitoring and <br /> sampling of your wells on the approved semi-annual and annual sampling schedules no later <br /> than 30 June 2012 and submit a report of findings to the EHD no later than 01 August 2012 . <br /> Your consultant may recommend changes to the approved monitoring schedule as long as the <br /> monitoring objectives are met and the plan is approved by the EHD . <br /> You also have been directed by EHD letters dated 01 December 2008, 11 March 2009 , <br /> 25 June 2009 and 18 May 2011 to submit a feasibility report for conducting additional <br /> remediation of impacted groundwater and a work plan to complete the lateral delineation of <br /> impacted groundwater; neither the feasibility study nor the work plan has been submitted to the <br /> EHD . You were directed to submit the feasibility study and the work plan for additional <br /> delineation of impacted groundwater to the EHD within 30 days of date of the 18 May 2011 <br /> letter. The directed reports have not been submitted to the EHD or to GeoTracker. You are now <br /> directed to submit the report and work plan to the EHD no later than 01 August 2012 . Please <br /> note that the EHD is under obligation to move all sites toward closure and you missed the 30- <br /> day due date set by the 18 May 2011 letter. If the EHD cannot move your site to closure , then <br /> your site must be referred to the Central Valley Regional Water Quality Control Board <br /> (CVRWQCB) for enforcement action ; failure to meet the deadlines established in this letter will <br /> be considered evidence that you will not be responsive to the EHD directives and your case will <br /> be referred to the CVRWQCB. <br /> If you have any questions or comments regarding the issues in this letter, please contact Vicki <br /> McCartney , REHS , at (209) 468-9852 , or Nuel Henderson , PG , at (209) 468-3436 . <br /> A <br /> Victoria L McCartney, REHS Nuel C . Henderson , Jr. , PG <br /> Senior Registered Environmental Hea Specialist Engineering Geologist <br /> C : James Barton , RWQCB , 11020 Sun Center Dr. #200 , Rancho Cordova , CA 95670 <br /> C: Arthur Diecke , AGE, 837 Shaw Road , Stockton , CA 95215 <br /> LIAR Request Response Letter 0312 <br />