COMPLIANCE INFO_1997-1999 - Laserfiche WebLink

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Additionally, if you have any MTBE, other fuel additives, or any other contaminant data previously collected at your site that has not been submitted to PHS/EHD, you are requested to submit this data immediately and update cumulative data tables accordingly. We request that you employ approaches to estimating MTBE/Additive/Solvent contaminant mass flux across plume transects or fences located perpendicular to the MTBE/Additive plume. We request the use of expedited site assessment tools and/or appropriately screened monitoring wells to provide data for these estimates. In deciding the location of transects and developing mass flux estimates, please consider the variable dissolution of MTBE from the source. We request that you install permanent monitoring wells and/or monitoring well clusters(screened at appropriate discrete depths with appropriate length of screen) to monitor the plume. Include your proposal for the installation of these wells in the work plan amendment requested below. Please report your results in the SWI Report requested below. We request that you monitor the groundwater contaminant plumes on a quarterly basis. Additional wells will be required to define the down gradient extent of the plume if the plume continues to migrate or the first set of wells fail to define the plume(s). In the event continued plume migration is identified,or impact to the Public Water Supply Well is predicted please include recommendations for the installation of additional wells or remediation alternatives in the Quarterly Reports requested below. Task 6 of the REE workplan cannot be approved or implemented at this time. Corrective Action Regulation requires responsible parties to evaluate and present for review potentially effective remediation alternatives (more than one). Implementation of this scope of work at this stage is premature recognizing the site is not appropriately defined and the proposal lacks defined vapor extraction monitoring/testing details. Please omit this portion of the proposal until a more comprehensive assessment report is available. In addition please omit any references to the Bay Area Air Quality District from Appendix A as the permitting authority and refer only to appropriate regulatory agencies. Task 7 of the REE workplan is inappropriate since California has not officially adopted any form of an ASTM/RBCA Tier I Table due primarily to tremendous variability in hydrogeoiogic settings. Please omit this portion of the proposal until an approved Tier I approach is available in California. In addition, it is likely the Tier I assessment would fail to provide site closure given the known groundwater contamination and close proximity of the on-site public water supply well. Please submit technical reports to the San Joaquin County Public Health Services Environmental Health Division(PHS/EHD),Attention: Ron Rowe, according to the following schedule: • October 14,1997, 5:00 pm-Work Plan Addendum for completion of SWI • 45 days from work plan submittal-Soil and Water Investigation(SWI)Report • 210 days from work plan submittal-Corrective Action Plan We request that all required work be performed in a prompt and timely manner under the direct supervision (witnessed)of PHS/EHD staff. We have proposed a schedule for the submittal of the SWI Report and the CAP. Revisions to the proposed schedule shall be requested in writing with appropriate justification for anticipated delays. Failure to comply with this corrective action directive may result in referral to the District Attorneys office. PHS/EHD recommends that all site assessment and remediation related activities in which the responsible party(s)engages in and anticipates reimbursement from the Underground Storage Tank Cleanup Fund(USTCF)be reviewed and pre-approved prior to commencing work. 4