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/jAA EX CV.( W0CB ; <br /> G MOV 20 PH 3 p� 11244 PyritesWay- Gold River,(A 95670 <br /> E N V I R 0 T E f H , I N f . Phone 916, 1,0174• Fax 916.851.0177• Toll Free 1.800.242.5249 <br /> November 20, 2006 <br /> W.Brian Newman <br /> CRWQCB <br /> 11020 Sun Center Drive,#200 <br /> Rancho Cordova, CA 95670 <br /> Subject: Response to Draft Cleanup and Abatement Order <br /> Dear Mr.Newman: <br /> This letter was prepared to provide comments on the Draft Cleanup and Abatement Order <br /> No.R5-2006-XXXX prepared by the California Regional Water Quality Control Board- <br /> Central Valley Region(CRWQCB)dated November 1,2006 for the Shell Petroleum <br /> Station located at 6437 Banner Road,Lodi, California. The comments are as follows: <br /> Page 2,Item 5—The CRWQCB states that Flag City Chevron placed monitoring wells <br /> down gradient of the Site's USTs. <br /> Flag City's consultant stated in reports that the groundwater flow direction was to <br /> northeast for over 10 years. The typical northeast groundwater flow direction would <br /> place Flag City Chevron's well MW-19 upgradient of the Site's USTs and downgradient <br /> from Flag City Chevron. However, six quarters of groundwater monitoring data from <br /> the site suggest that the groundwater flow direction from the site is southwest which <br /> places Flag City Chevron's well MW-19 in a down/cross gradient direction. <br /> Page 2,Item 6—The CRWQCB states that the Site did not submit a workplan by July <br /> 15,2005 as required. <br /> Apex did submit a Workplan on that date and received a letter from San Joaquin County <br /> Department of Environmental Health requesting a workplan addendum,which Apex <br /> submitted on July 22, 2006. <br /> Page 2,Item 6—The CRWQCB states that MTBE was detected in well MW-3A and in <br /> well MW-4B but not MW4A,which indicates that the MTBE plume was migrating <br /> verticallywhile being transported in the down gradient groundwater direction. <br />