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STATE Of CALIFORNIA ( 7 GEORGE DEUKMEJIAN.Governor <br /> CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD— <br /> CENTRAL VALLEY REGION -� <br /> 3443 ROUTIER ROAD <br /> SACRAMENTO,CA 95827.3098 <br /> D <br /> 4 April 1988 SFR HEp,�[H <br /> EN�IRRM�jSERVICES <br /> Mr. Michael Hansen <br /> Kayo Oil Company <br /> P.O. Box 190 <br /> Lodi, CA 95241 <br /> PROBLEM ASSESSMENT REPORTS (PAR) FOR�8.0.0,-EAST.-HIGHWAY:-12 IN`-L-ODI <br /> y,. _-��.— ..,_.s.-.•--�__ <br /> civ — �— <br /> AND EAST 4'3-2�5�-WASHINGTON' STREET `ITOCKTONThank- ou for submittin tY e' trio RS p -a. <br /> y- g prepared by Groundwater <br /> Bioremediation Services (a Du Pont subsidiary) . The reports, <br /> nearly duplicates of each other, were submitted together and have <br /> basically the same problems; i.e. , the following information was <br /> not included: <br /> - Results and data from the Step-Drawdown Test conducted at <br /> each site. <br /> - Raw data sheets for the recent ground water analyses. <br /> - The proper signatures of certification and. registration are <br /> lacking. California law requires that "public" reports <br /> containing geologic and/or engineering information be signed <br /> by a properly certified or registered individual. Reports <br /> sent to any Regional Board or other regulating agency are <br /> "Public" . <br /> Both reports have other areas which require further evaluation <br /> and clarification: <br /> - The reports, and subsequent phone conversations, indicate <br /> that _the constant rate pumping tests (CRPT) at each site <br /> were performed at rates basedlon Step-Drawdown data (which <br /> were not in the reports) . The CRPT were each designed to <br /> run for 24 hours but had to be curtailed after 12 hours at- Al <br /> 4325 Washington Street and 18 hours at 800 East Highway-12 <br /> due to aquifer dewatering. Your consultant for the tests <br /> completed a Cooper-Jacobs analysis of the pumping test data <br /> even though most assumptions for use of this analytical <br /> method were not met. Also, the units of transmissivity are <br /> inconsistent in the reports (g,pd/ft versus gpf/d) . <br /> - At each site the benzene plume of contamination has been <br /> adequately defined; however, the total petroleum hydrocarbon <br /> (TPH) plume has not. The extent of TPH contamination at <br /> both sites has not been determined nor has any explanation <br />