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Sent, By: Rl;'OC8 SACRAMENTO; 916 255 3015; Apr-6-99 8:30; Page 317 <br /> State Wer Resources Control Bard <br /> Divbloa of Clean Water Programs <br /> Wisesan H.fHirkox 2014 r serves•Swrsmmmo.Cslabmis 93516•(916)227-4399 Cray Davis <br /> MlailingAddrva PD.Box 9aa212•SWUKV 9-Csliforoia'9424144119 <br /> EXVtMXek+uaf FAX(906)227-6340 <br /> pftkvdoff <br /> TO: Jaynes George Giannopoulos tb <br /> C;hiec Regulatory Programs B <br /> Edward C. Anton.Chief <br /> Division of Clean Water Programs <br /> FROM: Dennis Parfitt <br /> Associate Engineering Geologist <br /> DIVISION OF CLEAN WATER PROGRAMS <br /> DATE: MRP 2 2 'cNig <br /> SUBJECT: RESPONSE TO REGIONAL BOARD STAFF COMMENTS REGARDING <br /> DRAFT ORDER FOR CLOSURE OF UNOCAL-UST SLTE AT <br /> 1665 PACIFIC AVE.,STOCKTON,SAN JOAQUIN COUNTY <br /> a <br /> In their review of the draft order regarding the subject site.Central Valley Regional Board staff <br /> stated that the order was"inalgpmpriatc and prematu'V'because it contained factual errors and <br /> did not consider water quality and other data collected at the site in January of 1999. The issues <br /> as to whether or not site conditions represent a threat to current or anticipated beneficial uses of <br /> groundwater or public health and safety were not directly addressed. tea,Regional Board <br /> staff merely pointed out that four Cahfbmia water Scmc-c(CWS)suPPiy wells located within <br /> 3,000 feet of the site have sanitary seals which do not extend more than 96 feet below ground <br /> surface, and further asserted that nothing prevents CWS(or any other interest) from constructing <br /> a well near the site. Regional Board staff also contended that high concentrations of petroleum <br /> constituents in soil wkd groundwater are identified more than 150 feet offsite and that without the <br /> assessment information obtained in January of 1999,and an estimate of the mass of <br /> hydrocarbons in soil and groundwater,plume stability could not be evaluated- <br /> 1 have reviewed the report of the recent work completed at the site in January and February <br /> of 1999,and find that it contains no new information that would alter the conclusions and <br /> recommendation for closure presented in the drag order. Rather,these new data confi.7. the site_' <br /> conceptual model upon which the draft order is based. A discussion of relevant issues is <br /> presented below. <br /> PN—Cadifoornia nviroRwceniat Protecdor Agency <br /> SURNAME Z 0xM'00dpq., .- •�� <br /> own seo *tr.-1/56 <br />