SITE INFORMATION AND CORRESPONDENCE

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CLEANUP AND ABATEMENT ORDER N0•007-0709 -q J. GILBERT MOORE, EILEEN A. MOORE,AND NEW WEST PETROLEUM. INC. NEW WEST PETROLEUM#1003/FLAG CITY SHELL LODI, SAN JOAQUIN COUNTY downgradient from the LISTS, and approximately 500 feet upgradient from CSA-31 Well 2. MtBE was not detected in the deeper well MW-6C (74 feet bgs) at the same location. 14.On 17 November 2005, SJCEHD directed the Dischargers to conduct an Enhanced Leak Detection (ELD) tracer gas test. The ELD tracer gas test was conducted 18 January 2006. The ELD report showed no tracer gas vapor leaks, however, a vapor recovery bucket for the 87 octane tank failed containment in a separate watertight test, indicating that vapors and/or vapor condensate could be released to the unsaturated zone and to underlying groundwater, 15.On 5 December 2005, MtBE was detected at 210,000 pg/L and Tertiary Butyl Alcohol (TBA, a potential MtBE degradation product) was also detected at 260,000 pg/L in the onsite Extraction Well EW-4. Benzene (1.1 pg/L) and Toluene (1 pg/L) were also detected on that date in MW-6B. 16.On 30 March 2006, APEX submitted a letter to SJCEHD proposing installation of additional monitoring wells. The SJCEHD verbally approved APEX's proposal during the meeting on 30 March 2006, and the work plan was submitted 24 April 2006, and approved by a SJCEHD letter dated 8 May 2006. The new wells were installed between 17 and 31 July 2006. On 17 July 2006, Regional Board staff verbally requested that the Dischargers install an additional deeper well MW-9D, screened at approximately 100 feet bgs, due the close proximity (175 feet) of MW-9B and MW-9C to CSA-31 Well 2. The CSA-31 Well 2 is screened from 100 to 150 feet bgs. On 2 August 2006 Regional Board staff collected a split groundwater sample from MW-9D (95 feet bgs). On 3 August 2006, the Regional Board contract lab reported the MtBE groundwater result for MW-9D as non-detect at <0.50 pg/L. 17. In an e-mail dated 14 June 2006, SJCEHD notified Regional Board staff that the primary Flag City supply well CSA-31 Well 1 was off-line for up to 6 weeks due to mechanical failure, necessitating the use of CSA-31 Well 2, nearest the MtBE plume. On 16 June 2006, the SJCEHD directive letter required the Dischargers to begin weekly sampling of CSA-31 Well 2 in order to protect human health. In an e-mail received by SJCEHD on 20 June 2006, APEX responded, "...Flag city chevron should also be responsible for half this work. Apex recommends conducting this work on a bi-weekly basis with Chevron doing the alternate weeks..." The Dischargers did not comply with the SJCEHD directive to sample the CSA-31 Well 2 during the week of 18 through 24 June 2006. Regional Board staff consulted by phone with SJCEHD on 21 June 2006, and, due to the MtBE threat to CSA-31 Well 2, a consensus was reached to transfer lead regulatory status from SJCEHD to the Regional Board, By SJCEHD letter dated 21 June 2006, the lead agency status for the Site was transferred to the Regional Board. The Regional Board letter of 27 June 2006 reiterated the weekly sampling of CSA-31 Well 2, and on 28 June 2006, APEX sampled the well. The CSA-31 Well 1 was subsequently repaired and placed back in service as the primary production well, and on 6 July 2006, both Regional Board and SJCEHD staff agreed to require monthly sampling for CSA-31 Well 2. A 7 July 2006