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Winston H. Hickox <br />Secretary for <br />Environmental <br />Protection <br />California Regional Water Quality i control <br />Central Valley Region <br />Robert Schneider, Chair SFP I -1 PM I: 04 <br />Sacramento Main Office <br />Internet Address: http://www.swrcb.ca.gov/--rwqcb5 <br />3443 Routier Road, Suite A, Sacramento, California 95827-3003 <br />Phone (916) 255-3000 • FAX (916) 255-3015 <br />Gray Davis <br />Governor <br />15 September 2003 <br />Mr. Sheldon Heckman, c/o Kama E. Henigfeld <br />Herum Crabtree Brown <br />2291 W. March Lane, Ste. B-100 <br />Stockton, CA 95207 <br />REPORT REVIEWS, FORMER CONNELL MOTOR LIFT TRUCK/RIVER CITY PETROLEUM, 2211 <br />NORTH WILSON WAY, STOCKTOIV, SAN JOAQUIN COUNTY <br />Former Connell Motor Lift Truck (Connell) and River City Petroleum (RCP) existed on property owned by you, <br />at 2211 North Wilson Way, Stockton, San Joaquin County. The two sites are located on opposite sides of a tire <br />warehouse, with Connell on the west and RCP on the east. A Stoddard Solvent (TPHss) release at Connell was <br />investigated under Regional Board staff oversight in the Spills, Leaks, Incidents, and Cleanup Section. A <br />petroleum hydrocarbons and 1,2-dichloroethane (1,2-DCA) release from RCP's Underground Storage Tanks <br />(USTs) was investigated under the Local Oversight Program of San Joaquin County Environmental Health <br />Department (SJCEHD). On 9 January 2003, SJCEHD referred RCP to the Regional Board. <br />I reviewed the following documents submitted by your consultant Advanced GeoEnvironmental Inc. (AGE) for <br />Connell: <br />Corrective Action Plan (CAP) dated 7 February 2003; <br />Quarterly Report — First Quarter 2003 Monitoring Report; dated 24 February 2003; <br />Quarterly Report — Second Quarter 2003 Monitoring Report; dated 9 July 2003, <br />and by your consultant Foothill Engineering (FE) for RCP: <br />Installation of CPT#1 to CPT#5 and Associated Soil and Water Sample Analysis, dated <br />5 May 2003, <br />First Quarter 2003 Monitoring Well Sample Analysis Report, dated 13 May 2003, and <br />Second Quarter 2003 Monitoring Well Sample Analysis Report, and Installation of Monitoring We! <br />MW#1D Report, dated 15 August 2003. <br />Comments: <br />The TPHss and 1,2-DCA plumes are commingled. Currently you are conducting a separate <br />investigation/remediation for each release. Neither investigation, nor the proposed remedial options are intended <br />to address the entire commingled plume. Because the RCP site is collecting State UST Cleanup Funds, and <br />because it is more cost effective to conduct a single investigation, Cormell and RCP shall be combined under one <br />cover for all future reports, proposals, and worlcplans. Future documents for Connell and RCP shall include one <br />site figure showing all wells. All wells will be renumbered in a sequential manner. Unique well symbols may be <br />used to define the origin of the monitoring wells in the figure. Footnotes may be used to further define the source <br />of the data and identify aquifer zones screened in the tables. One set of tables shall incorporate all of the <br />historical analytical data. Another table shall include all of the most recent quarter groundwater results. Site <br />maps and cross-sections should show the contaminated soil and groundwater plumes. Geologic cross-sections <br />are required and must be presented within the framework of a site conceptual model, which will include all data. <br />A Site Conceptual Model (SCM) is necessary for this complex site, and will need to be reviewed quarterly and <br />California Environmental Protection Agency <br />2' Recycled Paper