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California ogional Water Quality Conol Board C@W,� <br /> Central Valley Region Karl E.Longley,ScD,P.E.,Chair <br /> Linda S.Adams Arnold <br /> Sacramento Main Office <br /> Schwarzenegger <br /> Secremrt,/o' 11020 Sun Center Drive#200. Rancho Cordova.California 9567(}6114 <br /> Emn iectionnl Phone(916)464-3291 •FAX(916)4644645 Governor <br /> htip.//%vim.i%,aterbouds.ca.gov/centralvalley <br /> 26 July 2007 <br /> Mr. Gil Moore 19FCE�� <br /> New West Petroleum, Inc. <br /> 1831 16th Street AUG 0 2 2007 <br /> Sacramento, CA 95814 <br /> ENVIRONMENT HEALTH <br /> PERMIT/SERVICES <br /> DOCUMENT REVIEWS, NEW WEST PETROLEUM #1003 (SHELL BRANDED), <br /> 6437 BANNER STREET, LODI, SAN JOAQUIN COUNTY(CAO R-5-2007-0709) <br /> I reviewed the following documents, submitted by your consultant Closure Solutions, Inc. (CSI) <br /> in response to the 16 July 2007 deadlines in the Regional Board Cleanup and Abatement <br /> Order No. R5-2007-0709 (CAO): <br /> Work Plan for the Installation of Off-Site Groundwater Monitoring Wells and Soil Vapor <br /> Survey (Workplan), <br /> • Site History, <br /> • UST System Integrity, and <br /> Public Participation Plan. <br /> The Workplan proposes installation of four downgradient groundwater monitoring wells <br /> MW-10A, -10B, -10C, and MW-11 B to the southeast of the Site (enclosed Figure 1), and the <br /> installation of four soil vapor sample probes (enclosed Figure 2) near buildings adjacent to or <br /> above the groundwater plume. Depth to water was approximately 13 to 15 feet below ground <br /> surface in March 2007. The Site History provides a listing of property owners and tank <br /> operations from installation to date. The UST System Integrity report provides the tester's <br /> clarification of results, and emails concerning, the Enhanced Leak Detection (ELD) Test <br /> conducted in 2006. The Public Participation Plan provides a draft notice to adjacent <br /> landowners and interested parties of a Corrective Action Plan required by the CAO. <br /> I have the following comments on the documents submitted: <br /> Workplan: <br /> 1. The Workplan does not address the need for lateral definition of the groundwater plume <br /> to the north and northeast of the LISTS. In an email dated 9 July 2007, 1 notified CSI <br /> that San Joaquin County Environmental Health (SJCEHD) stated in verbal <br /> communication to me that two supply wells, a municipal well (CSA-31, Well #3) and the <br /> Flying J Irrigation Well (enclosed Figures 3 and 4), will commence operations to the <br /> northeast of the Site at the Flying J Truck Stop. The Site and the Flying J Truck Stop <br /> are on opposite sides of Highway 12. My records show that CSI also contacted the <br /> SJCEHD by email on 9 July 2007 for information on the new wells, and received a <br /> general description of their locations. In an email and a voicemail received <br /> California Environmental Protection Agency <br /> ped <br /> Recycled Paper <br />