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Evaluation of Natural Attenuation_ 7500 West Eleventh Street, Tracy, CA. Page 4 <br /> in the interior of the plume of affected groundwater emanating from the 7500 West <br /> `! Eleventh Street property. The thickness of floating product in those five wells was <br /> checked at that time and tests were also made to detect the presence of LNAPL on the <br /> water table in groundwater-quality monitoring wells MW-7, MW-13 and MW-14. The <br /> same array of wells was again checked for the presence of floating product on July 26 <br /> and October 27, 2004, The historical record of LNAPL thickness measured in the array of <br /> floating product monitoring wells through October 27, 2004 is presented in Table 3. <br /> Table 3 also includes the results of measurements of LNAPL thickness in the array of <br /> floating product monitoring wells that was conducted on February 24, 2005 in association <br /> with the evaluation of natural attenuation conducted on the site. <br /> i <br /> 1.3.4 Testing of Water in Potable Water-supply Wells <br /> At the direction of the SJCEHD, the quality of water in six potable water-supply wells in <br /> the neighborhood of the Navarra Site was analyzed in April 2004. Second and third <br /> rounds of sampling and analysis of the water produced from those wells were conducted <br /> on July 27 and October 28, 2004. This report includes the results of the fourth quarterly <br /> monitoring round of that program, which was conducted on February 25, 2005. The <br /> results of those four sampling rounds are recorded in Table 4. <br /> 1.3.5 Recommendations for Evaluation of Natural Attenuation <br /> r <br /> ' Based on our extensive experience with fuel hydrocarbon contamination at sites similar <br /> 1= to the Navarra Site, by December 2003, it was clearly apparent to SJC that the historical <br /> results of the groundwater-quality evaluation program that had been on-going since May <br /> 2000 indicated that natural processes were acting to significantly attenuate the <br /> = concentrations of chemicals of concern at the 7500 West Eleventh Street property. <br /> Accordingly, as we have done on many other occasions (2004c, 2004e, 2003e, 2002a, c); <br /> SJC reconunended that the scope and frequency of the groundwater-quality monitoring <br /> program be revised to reduce unnecessary expense to the California Underground Storage <br /> Tank Cleanup Fund (USTCF), while maintaining sufficient elements of the monitoring <br /> program to ensure that some unexpected behavior of the groundwater plume did not <br /> '- ' develop and increase risks to the environment of the site and its adjacent areas. SJC <br /> proposed that an evaluation of natural attenuation of contaminants in groundwater be <br /> conducted based upon a formal assessment of primary and secondary evidence. That <br /> proposal, which was supported by an engineer's estimate of the cost of its <br /> implementation, was included in SJC's work plan for refinedplume definition and <br /> .� management of floating product (The San Joaquin Company Inc. 2003a) and reiterated in <br /> the October 2004 quarterly groundwater-monitoring report (The San Joaquin Company <br /> Inc. 2004b). <br /> Finally, at a meeting requested on December 15, 2004 by SJC and held at the Stockton <br /> offices of the SJCEHD on January 18, 2005, attended by representatives of the SJCEHD, <br /> the RWQCB and SJC, the staff of the regulatory agencies requested that a formal <br /> evaluation of natural attenuation at the Navarra Site be performed. The groundwater <br /> sic <br /> J <br />