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RECEIVED APR 1 n "007 OL <br /> Era 0 a :oc",r, <br /> SATIN JOAQUUq COUNT Y' <br /> a c <br /> /''�`4' `'`'qC• Program Coordina-fan; <br /> .donna fC. Herat,, R,E.R.S. <br /> N's ` Directoa 304 East Vi eberkvenue,Third Floor Carl so�Rman, K.L.H.s. <br /> _ Mike Huggins, R,E.H.S., R.D.T. <br /> t,s Brie A. co4�rlia, .E.rZ.s. Stockton,Cab 85202-2708 <br /> \\'; :.� • Margaret Lagorio, R.E.H.S. <br /> rt.csi,el2nt rirector Telephone: (209)46o- 420 Robcrf t��cClellon, K.F..Id.S. <br /> 1'= (209)464-01.38 lerf Carruesco, R.E.B.S. <br /> VJebsite:vrv-rw•sjgov.org/ebd/ Kasey Foley, R.F..H.S. <br /> JERRY MOORE 'APR 112801 <br /> MOORE PETROLEUM <br /> W MARIPOSA AVE <br /> ST Ad (O "' <br /> STOCKTON CA 95204 <br /> RE: Quarterly Monitoring Report Recommendation and the Proposed <br /> Cancellation of the MW-15 Installation. <br /> 5491 F Street <br /> Banta CA 95304 <br /> San Joaquin County Environmental Health Department (EHD) has received and <br /> reviewed Third Quarter 2006 Groundwater Monitoring and Remediation Report, dated <br /> 19 December 2006, First Quarter 2007 Groundwater Monitoring and Fourth Quarter <br /> Remediation Status Report, dated 08 February 2007, the letter dated 22 February 2007 <br /> with the subject Update on Status of Proposed Monitoring Well MW-15 (letter), and <br /> Limited Subsurface Site Investigation Results Report(site investigation report) dated 30 <br /> March 2006, all prepared by Apex Envirotech, Inc. (AEI) on your behalf. <br /> Both quarterly reports recommend reducing the monitoring frequency of monitoring wells <br /> MW-5 and MW-6 to an annual basis. Based on the locations of these wells and their <br /> monitoring history, the EHD approves this recommendation. Additional reductions of <br /> sampling select wells and/or reductions of the analytical regimens will be considered by <br /> the EHD if proposed by you with an adequate demonstration that all monitoring <br /> objectives will still be met with the proposed reductions. <br /> In their February letter, AEI recommends waiving installation of the approved monitoring <br /> well MW-15 as the railroad company that owns the land is not being cooperative with <br /> you, the costs to install it are deemed to be unreasonably high and the groundwater flow <br /> direction has shifted toward the north over the last year of monitoring. The EHD cannot <br /> approve waiving installation of the previously approved MWA 5 for the following reasons: <br /> • Installation of MW-15 was approved to delineate and monitor the dissolved <br /> plume in the down-gradient direction. The Central Valley Regional Water Quality <br /> Control Board (CVRWQCB) generally will not concur with closure requests for <br /> sites lacking complete dissolved plume delineation. <br /> • Sensitive Receptor Survey Results (SRSR), dated 16 August 2006, prepared by <br /> AEI, identified 33 domestic water wells within a 2000-foot radius of the site, 19 of <br /> which are within 500 feet of your site. The high groundwater usage in this area <br /> increases the importance of complete plume delineation for your site. <br />