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California Tank Lines, Inc. Page 3 <br /> 3105 South EI Dorado Street August 17, 2011 <br /> Stockton, California 95206 <br /> Based on the high petroleum hydrocarbon concentrations detected in groundwater from MW-4 <br /> at the California Tank Line site, and MW-7 and MW-1 at the Pacific Pride facility, one would <br /> expect to find high contaminant concentrations in groundwater collected between these <br /> impacted areas if the southern site is the source of contaminants impacting MW-4 on the <br /> subject site; however, this is not the case. Based on this review, it does not appear that the <br /> petroleum hydrocarbon contamination detected in groundwater from MW-4 came from the <br /> Pacific Pride facility. If your consulting firm can demonstrate that the petroleum hydrocarbon <br /> contaminants detected near MW-4 are not related to the former USTs on your site, the EHD will <br /> refer the case to the Spills, Leaks, Investigations, and Cleanups (SLIC) program of the <br /> California Regional Water Quality Control Board Central Valley Region. <br /> Taber compared doing no remedial action at this site to several active remedial methods: pump <br /> and treat (groundwater extraction); dual phase extraction; air sparging/in-situ chemical <br /> oxidation; free product removal by bailing; and monitored natural attenuation (MNA). Taber <br /> concluded that free product removal by bailing groundwater from MW-2 is the best remedial <br /> method to remove petroleum hydrocarbon contamination in the area of the former waste oil <br /> tanks; and MNA is the recommended remedial method to remove contaminants of concern in <br /> the area of MW-4. <br /> Taber also recommends that an additional monitoring well (MW-5), screened between 17 and <br /> 37 feet bsg, be installed adjacent to MW-2. Since depth-to-groundwater measurements taken in <br /> February 2011 were approximately 25 feet bsg, this new well may enhance the removal of free <br /> product that is currently above MW-2's screened interval of 30 to 50 feet bsg. Taber proposes <br /> to continuously log the borehole to total depth of approximately 40 feet bsg. Although Taber <br /> does not illustrate the proposed location of MW-5 in any of the Figures presented in the CAPFS, <br /> the EHD approves the work plan for installing MW-5 adjacent to MW-2. Submit a boring/well <br /> permit application permit/inspection fee to the EHD and complete the well installation by 01 <br /> November 2011. (Please note that the EHD's hourly fee has increased from $122 to $125 per <br /> hour.) <br /> The EHD also approves the pilot test using disposable bailers to bail free product from both <br /> MW-2 and newly-installed MW-5. Taber proposes to remove the free product daily for a period <br /> of one week or until the free product recovery rate has stabilized. If necessary, Taber proposes <br /> to use a skimmer if hand bailing fails to keep up with the recharge. Taber proposes to use <br /> existing data and collect additional data to input into the Bioscreen model to: <br /> • Predict the future extent and concentration of the dissolved-phase contaminant plume <br /> by modeling the effects of advection, dispersion, sorption, and biodegradation; <br /> • Assess the possible risk to potential down-gradient receptors; and <br /> • Provide technical support for selection of the MNA option as the best remedial <br /> alternative." <br /> The EHD approves the collection of the MNA parameters as proposed by Taber. The data will <br /> be used in the Bioscreen model to determine: <br /> • Natural degradation rates; <br /> • Fate and transport of dissolved degraded fuel hydrocarbons; and <br /> • Potential risk to human health and the environment. <br />