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Joe Panetta — JNL Farms <br />95 W. 11 th St., Tracy. <br />page 2 <br />The development of the property began without notification to the EHD and <br />resulted in a majority of the monitoring wells being damaged or lost from the <br />grading at the site. Although the monitoring wells were found and repaired, your <br />urgency to develop the site continues. You may not have adequately taken into <br />your planning the requirements to investigate and remediate the contaminant <br />impact to soil and groundwater from the former underground storage tanks. <br />Investigative and remedial costs may be significantly higher because the work <br />will now have to occur under and around a building. Since your petroleum <br />groundwater plume is not laterally or vertically defined at this time, after the <br />building is complete the required investigation may include multiple costly slant <br />borings or remedial well installations. <br />EHD strongly recommends you reevaluate your plan of action for this site and <br />proceed with the most cost-effective approach. Aggressive investigation and <br />remedial action to clean up the site should be taken before the building is started. <br />The corrective action approach proposed now is based on meeting building <br />requirements and may not be cost-effective. This could jeopardize any <br />reimbursement costs from the State Water Resources Control Board (SWRCB) <br />Clean Up Fund if the site is determined to be eligible for reimbursement costs. <br />EHD approved a request to start some of the work included in this plan before <br />this written approval was completed and issued. An appointment for the <br />destruction of the three monitoring wells was taken for September 15, 2003 and <br />MW -1, 3, & 4 were properly destroyed on that date. <br />The boring permit for the additional monitoring well installations has not been <br />submitted and therefore may not proceed. The public participation period is still <br />in progress and the over -excavation cannot start without EHD approval after the <br />comment period is over. <br />Please continue to forward your comments and submittals to Michael Infurna or <br />you may contact him at (209) 468-3454. <br />Donna Heran, RENS, Director <br />Enviro ental Health Divisi <br />ichael J. Infurna Jr., enior RXHS <br />LOP - Site Mitigation Unit IV <br />Margare agorio, RENS <br />Supervisor <br />MI/ <br />c: CVRWQCB — J.L.L. Barton, Sacramento. <br />c: AGE - Donna Sexton 837 Shaw Rd, Stockton. 95215 <br />c: -JLN Farms - Joseph Nomellini, 13084 E. Hwy 26, Stockton 95205. <br />