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TANK MONITORING <br /> Since complete full system testing cannot be accomplished on the three tanks, the only <br /> feasible alternative is to dispense the tank testing and implement monitoring as per Title <br /> 23 requirements. Accordingly, AEMC recommends installation of groundwater <br /> monitoring wells without vadose zone monitoring. This is a modification to Alternative 2, <br /> Section 2641,Title 23, for the following reasons: <br /> 1. No. 6 fuel oil gives off little to no vapor; therefore rendering vapor or vadose <br /> zone monitoring wells ineffective. <br /> 2. Based on information provided by Gold Bond on the specific gravity of the <br /> No. 6 fuel oil held in the tanks, the product will float on water and therefore <br /> show up in a monitoring well if a leak were to occur. <br /> 3. Depth-to-groundwater in the vicinity of the tanks is relatively shallow, ranging <br /> from ten to fifteen feet,which would allow for early detection of a leak before <br /> it becomes a major problem. <br /> Monitoring Wells <br /> AEMC proposed to install monitoring wells at the tentative locations shown on <br /> Attachment 3, Monitoring Well Locations. Monitoring Wells 1 and 2 are intended to <br /> monitor 90 barrel tanks. <br /> Although three wells are required in the regulations, access near the tanks limits the <br /> feasible number of wells to two. Considering that the tanks are only about fifteen feet in <br /> the longest dimension, this should not affect the effectiveness of monitoring. <br /> Monitoring Wells 3 and 4 are intended to monitor the 5,500 barrel tank. One well will be <br /> placed upgradient and the other downgradient to meet Title 23 requirements. <br /> s <br /> �„��z� Page 3 <br />