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Arnold <br />Schwarzenegger <br />Governor <br />Linda S. Adams <br />Secretary for <br />Environmental <br />Protection <br />California. egional Water Quality Cottrol Board <br />Central Valley Region <br />Karl E. Longley, ScD, P.E., Chair <br />11020 Sun Center Drive #200, Rancho Cordova, California 95670-6114 <br />Phone (916) 464-3291 • FAX (916) 464-4645 <br />http://www.waterboards.ca.gov/centralvalley <br />24 December 2008 <br />Certified Mail <br />7008 1140 0002 8805 5339 <br />Mr. Gurpal S. Sidhu <br />5410 Staples Way <br />Linden, CA 95236 <br />REQUEST FOR COMPLIANCE WITH SAN JOAQUIN COUNTY ENVIRONMENTAL HEALTH <br />DEPARTMENT DIRECTIVE TO RESTART ALL TREATMENT SYSTEMS, WATERLOO FOOD & <br />FUEL, 3032 E. WATERLOO ROAD, STOCKTON, SAN JOAQUIN COUNTY (LUSTIS # 390992) <br />In a letter dated 25 November 2008, the San Joaquin County Environmental Health Department <br />(SJCEHD) directed that the groundwater extraction (GWE) and soil vapor extraction (SVE) treatment <br />systems be restarted and run continuously immediately at the above site. Prior to this date, the City of <br />Stockton notified SJCEHD that, pursuant to a request from your consultant Advanced <br />GeoEnvironmental Inc. (AGE), the GWE treatment system permit would be terminated. This <br />termination action was conducted without prior notice to the SJCEHD, who subsequently received <br />confirmation that the GWE and the SVE treatment systems were offline. Prior to shutdown, the third <br />quarter 2008 remediation report stated GWE was removing 20 gallons of total petroleum hydrocarbons <br />as gasoline (TPHg) and SVE was removing over 750 gallons of TPHg, including methyl tert-butyl ether <br />(MTBE), per quarter. The total mass removed by both treatment systems since startup in 2006 <br />exceeds 39,000 gallons of TPHg. <br />The petroleum hydrocarbons groundwater plume emanating from your underground storage tanks <br />(USTs) release is currently undefined in the downgradient direction, has been detected onsite down to <br />150' below ground surface (bgs), has migrated offsite at least 500' feet downgradient from your site, <br />and may extend over 1,000' from your site (MTBE has been detected in Western Farm Service <br />monitoring well MW-20B, screened 95-110' bgs). A public supply well located 2,000' downgradient <br />from your site may be threatened by the MTBE plume. <br />Regional Board staff has been in communication periodically with the SJCEHD since November 2008, <br />and concur with SJCEHD that the magnitude of the impact to water quality, human health and the <br />environment if the public supply well, that is currently threatened, is impacted by your MTBE plume, <br />has been compounded by this treatment termination action. As such, Regional Board staff will be <br />attending the meeting scheduled for 6 January 2009 at the SJCEHD office in Stockton. It is imperative <br />that you attend and that the GWE and the SVE systems be in continuous operations mode prior to the <br />meeting, per SJCEHD directive. Failure to comply with the SJCEHD directive will result in immediate <br />transfer of lead agency status for the USTs case to the Regional Board, and subsequent issuance of <br />formal enforcement actions that include administrative civil liabilities (fines) up to $1,000 per day per <br />violation. <br />California Environmental Protection Agency <br />C5 Recycled Paper