SITE INFORMATION AND CORRESPONDENCE

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Attachment 4 Response to "Final Closure Plan" comments from the California Regional Water Quality Control Board - Central Valley Region dated March 27, 1990. Time Schedule A new project schedule is included with this submittal as Attachment 2. Excavation Water in the impoundment was sampled and analyzed and will be discharged (with written authorization from the City of Lodi) into the Lodi industrial waste water system. According to Jean McCue, the balance of comments under this heading were intended to establish the Water Board's position on these issues and therefore no -response is necessary. Closure of Monitoring Wells The quarterly groundwater monitoring report for January, 1990, as well as the year-end summary of groundwater data has been completed and submitted to the Regional Water Quality Control Board and the Department of Health, Toxic Substances Control Division. All of this data further supports our contention that "there has been negligible impact on the groundwater from the contaminated soil in the SI" . The detection limit for nickel was lowered from 0.05 mg./L to 0.01 mg./L for the January, 1990 groundwater samples. This is below any known health based water quality standard and still no nickel was detected. At the request of the Regional Water Quality Control Board, the detection limit for nickel will be lowered from 0.01 mg./L to 0.005 mg./L for the April , 1990 groundwater samples. Although there is no definition of "negligible impact" on groundwater, it is our position that since no health based water quality standards have been exceeded because of the contaminated soil in the SI , then there has in fact been "negligible impact" on the groundwater and the monitoring wells are no longer necessary to ensure protection of public health. Therefore the monitoring wells should be closed immediately following the excavation and refilling of the SI. k" 1 t,Y, •�F+y_4 4: ApR H�ST',