SITE INFORMATION AND CORRESPONDENCE_2004-2019

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2072 W. Yosemite Avenue • - 2 - 27 November 2006 was detected both north and south of the site. We explained that the movement of a plume can be complex and that plumes can move in different directions with depth and that there is evidence that this is occurring near the site. In addition, there had been no analytical data collected which suggests another source. Mr. Guinta questioned the value of the domestic well-head treatment systems and suggested that they were not needed because most of them were poorly constructed and the water in the area is of poor quality. He said that he did not understand why we were requiring on-going well- head treatment for wells with MTBE concentrations below the California Public Health Goal for toxicity of 13 ug/I. We explained that MTBE concentrations fluctuate with time in individual wells and the well-head treatment is needed to protect the public health. We informed him that the California Secondary MCL is 5 ug/I and that the goal is to clean up groundwater to background water quality concentrations, which a0pear to be below laboratory detection limits of 0.5 ug/I. Brian also explained that Board staff would be sampling wells in and around the MTBE plume on Tuesday and that analyses to assess overall water quality would include nitrates, coliform and metals. 3) Brian explained that a Corrective Action Plan was required to fully remediate the site and the plume(s) that extend from the site. Mr. Ramsey questioned how much it would cost to characterize the plume and conduct the remediation. We said that we could not estimate how much it would cost to complete the remediation since the extent of plume(s) has not yet been determined and there were insufficient recent on-site data. I said that a qualified consultant could prepare a cost estimate for remediation once there were sufficient data. Mr. Ramsey asked "when is enough, enough" to justify no more work at the site. Brian explained the general requirements and criteria for closure of an underground storage tank site. Specifically, an underground storage tank site can be closed when Regional Board staff concur that the petroleum source is removed or remediated, risks to public health and safety and ecological receptors are reduced to insignificant levels, and groundwater has been cleaned up to concentrations protective of existing and future beneficial uses. Mr. Ramsey said "the tasks will cost a lot of money in my personal view". Brian emphasized that additional field data would enable a consultant to more accurately estimate costs to complete all of the tasks. 4) We explained that based on our recent telephone conversations with City of Manteca staff, the City does not currently have plans to extend water supply lines to the north of the site where most of the domestic wells are impacted. Mr. Ramsey thought that it was worth looking at further since the construction of water supply lines may reduce or eliminate the need for domestic well-head treatment. However, he acknowledged that the Dischargers would still be required to implement the other tasks in the CAO. Mr. Ramsey said that he will contact the City of Manteca to further assess the status on any plans'for supplied water in the area. 5) We discussed funding issues. Brian stated that there are private loans such as the California Environmental Redevelopment Fund (CERF) for sites with contamination. The CERF website states that their loans are currently set at "prime plus 4% to 5%". Mr. Ramsey stated that he will evaluate whether either there are any insurance policies covering the period he owned the property and if there are, how much money may be available. Mr. Guinta emphasized that if he had any insurance money or other monies he would have used it to finish cleaning up the site. Brian stated that the Dischargers