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Report:Groundwater-qualityMonitoring—July 27,2004: 7500 West Eleventh Street, Tracy, CA. Page 19 Since very high concentrations of fuel hydrocarbons first appeared in Monitoring Well MW-7 in September 2001, SJC has requested authorization to implement an appropriate ' remediation program for that part of the site (Watkins 2000, The San Joaquin Company >i Inc. 2003a, 2003e, 2002c) but our persistent requests to address this issue have either passed without response or the proposals to implement a technically-sound remediation _ program in that area have been denied by the SJCEHD. Given the groundwater-quality data obtained by analyses of groundwater samples recovered from Monitoring Well MW- 7 (see Table 2), in April and July 2004, a critical programmatic decision must now be } made if fiuther wasteful expenditures of public funds are to be prevented. r-: There are two practical strategic options, the choice of which should be governed by the results of the coming October 2004 monitoring round. If the concentrations of the analytes of concern found in a sample recovered from Monitoring Well MW-7 in late October 2004 rise significantly, following the trend that has prevailed since January 2004, or if floating product appears in that or any other well in the floating product monitoring array, then: Remediation of affected soil and groundwater in the area to the east and west of Monitoring Well MW-7, along the north side of West Eleventh Street should be implemented, without further administrative process, by excavation of contaminated soil and pumping of affected groundwater and/or floating product from the resulting excavations into vacuum trucks for off-site disposal, according the site-specific trenching procedures detailed in SJC's Work Plan for Refined Plume Definition and Management of Floating Product at Former Fueling Station, 7500 West Eleventh Street, Tracy, California (The San Joaquin Company Inc. 2003 a). If the concentrations of the analytes of concern found in a sample recovered from Monitoring Well MW-7 in late October 2004 do not increase significantly compared to those in the sample recovered from that well in July 2004, then: 3 i A decision should be made that future management of the environmental condition of the 7500 West Eleventh Street site will not require active remediation and a program to assess the status of natural attenuation and bioremediation of fuel hydrocarbons in the subsurface and to assess the risk imposed by those that remain should be implemented according to the program that was also detailed in SJC's Work Plan for Refined Plume Definition and Management of Floating Product at Former Fueling Station, 7500 West Eleventh Street, Tracy, California (The San Joaquin Company Inc. 2003a). SJC requests that the SJCEHD decision with respect to the above site management E1 strategies be provided in writing to SJC and to the Navarras after that Agency receives our report documenting the October 2004 monitoring round, and before the round next thereafter is to be perfomed. sic