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GEoSYNTEC CONnLTANr$ <br /> Ms. Devra Lewis <br /> 23 January 2004 <br /> Page 2 <br /> until Agrium purchased Western Farm Service, Inc. (WFS) in 1995. At that <br /> point, the site began operating as WFS." <br /> • With regard to the installation of the cap/liner system mentioned in the,last <br /> sentence of paragraph one, Unocal was still responsible for all <br /> environmental liabilities at the site when the cap/liner system was placed. <br /> Therefore, we recommend changing the last sentence in paragraph one to <br /> "A cap/liner system was constructed over the two former evaporation ponds <br /> to prevent continued release of contaminants from the soil into the <br /> groundwater. The condition of the cap/liner system is monitored on an <br /> annual basis." <br /> • In the third and fourth paragraphs on page 1, we recommend the use of the <br /> term "destruction"instead of"abandonment." <br /> • In the second last sentence in the last paragraph on page 1, "schedule" <br /> should be changed to "scheduled". <br /> Key changes in the new MRP are: <br /> • Groundwater monitoring wells MW-19A/B, MW-20A/B, and MW-21 are <br /> now on semi-annual monitoring; and, <br /> • Chlorinated herbicides will now be monitored on an annual basis. <br /> Following RWQCB approval of the draft MRP, WFS will proceed with semi- <br /> annual groundwater monitoring activities. The next semi-annual report is due on I May <br /> 2004 and will include a thorough discussion of groundwater sampling results and <br /> trends, and a conceptual plan for the remediation of groundwater. <br /> 'APRJ2003REM\WFS.Stockton\STOI-Groundwater\Comment Revised MRP.doc <br /> rc�vcun aw retvwaiE A&k <br />