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California&gional Water Quality Cc }rol Board <br /> Central Valley Region <br /> Katherine Hart, Chair �°, <br /> Linda S. Adams Edmund G. Brown, Jr. <br /> Acting Secretary for 11020 Sun Center Drive#200, Rancho Cordova, California 95670-6114 Governor <br /> :nvironmental Protection Phone (916) 464-3291 • FAX (916) 464-4645 C <br /> http://www.waterboards.ca.gov/centralvalley RECEIVED <br /> 20 January 2011 AN 2 12011 <br /> Ms. Edna Moore, c/o Frank Moore ENVIRONMENTAL HEALTH <br /> Moore Truck Lines <br /> PERMIT/SERVICES <br /> P.O. Box 8307 <br /> Stockton, CA 95208 <br /> LEAD AGENCY STATUS, AND DIRECTIVES FOR UNAUTHORIZED RELEASE CASE NO. <br /> 391047, MOORE TRUCK LINES, 3400 NEWTON ROAD, STOCKTON, SAN JOAQUIN <br /> COUNTY(RB #391007) <br /> In a letter dated 20 December 2010, the San Joaquin County Environmental Health Department <br /> referred the lead agency for the above case to the Regional Water Quality Control Board <br /> (Regional Water Board) for failure to conduct semi-annual groundwater monitoring in 2010, <br /> failure to submit a vapor intrusion evaluation, and failure to implement the 2009 approved soil <br /> vapor extraction (SVE) pilot test for active groundwater remediation. Depth to water has varied <br /> from 53 to 73 feet below ground surface. The onsite domestic well is located 134 feet north of <br /> the tank pit. Groundwater flow direction is primarily towards the northeast at an average <br /> 0.007 ft/ft. Based on the last sampling event in November 2008, MW-5 through MW-8 and the <br /> site domestic well were non-detect for all constituents, and these wells have been consistently <br /> non-detect from February 2000 through November 2008. The groundwater plume appears to <br /> be a stable at MW-1 though not declining in concentrations. In February 2008, MW-1 had <br /> sufficient water and the sample analysis reported maximum groundwater concentrations for <br /> total petroleum hydrocarbons as gasoline, 400 micrograms per Liter (ug/L); and methyl tert butyl <br /> ether, 390 ug/L. <br /> On 28 December 2010, Regional Water Board staff met with your son Frank Moore, <br /> representing you, to determine the most practical and cost effective path to reach site closure. <br /> At the meeting we agreed to the following: <br /> • Only MW-1 would be monitored during the first quarter of 2011; <br /> • The vapor intrusion evaluation would be submitted; <br /> • The SVE pilot test was suspended; and <br /> • Your consultant would contact me to discuss the details for the work, including the schedule. <br /> Subsequent to the December meeting, William Little, Advanced GeoEnvironmental Inc (AGE) <br /> contacted me by phone on 14 January 2011 and again on 18 January 2011. On <br /> 14 January 2011 , AGE requested clarification on the minimum number of vapor samples, to <br /> assist them with their cost estimate to Mr. Moore, and stated that a limited soil vapor <br /> California Environmental Protection Agency <br /> Za Recvcled Paper <br />