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RCC www.rccgroupllc.net 417 Mace Boulevard, Suite J-284 Davis, California 95618 530.758.8128 (v) 800.878.2125 (f) July 18, 2011 MEMORANDUM via Electronic Mail and Priority Mail To: Mr. Michael Infurna San Joaquin County EHD Site Mitigation Unit IV mai Ito:mi nfurna(a)sicehd.com Subject: Transmittal of Monitoring Well Destruction Permits for Two MonierLifetile Facilities - San Joaquin County, California Dear Mike, Thank you for callback on Friday afternoon regarding the request for monitoring well destruction guidance. RCC Group, LLC (RCC) has been retained by MonierLifetile, LLC (Client or MLt) to permit, coordinate and conduct monitoring well abandonments at Client's two facilities in San Joaquin County, California. Specifically, these activities include the abandonments of six (6) groundwater monitoring wells at the two MLt facilities, which are located at 342 Roth Road in Lathrop and 9508 South Harlan Road in French Camp, California (the Sites). Project Understanding In preparation, RCC reviewed the technical submittal "Site Closure Request for MonierLifetile LLC Lathrop and French Camp Facilities- Lathrop and French Camp, California" dated June 21, 2010, which was prepared by others. Apparently, this document was addressed to Mr. Howard Hold at the Central Valley Office of the Regional Water Quality Control Board (RWQCB), and there was no indication that San Joaquin County Environmental Health Department (SJCEHD) Site Mitigation - Unit IV staff was on the distribution list for this submittal. In the unlikely event that SJCEHD staff was not provided this document earlier, the submittal can be summarized in these four elements: (1) confirms the completion of site assessment, groundwater monitoring, and removal and cleanup of onsite tile waste stockpiles for the Lathrop and French Camp MLt facilities; (2) provides the RWQCB with a brief summary of the work completed to date at both facilities that was requested in an earlier Cleanup and Abatement Order(CAO); (3) describes Site conditions in June 2010 at both facilities with respect to groundwater monitoring results and concentration trends; and (4) provides detailed rationale in support of a request for regulatory closure, on behalf of MLt. The request specifies that the RWQCB rescind the Order and grant regulatory site closure for the Lathrop and French Camp facilities. Other than data regarding the total depths of all six monitoring wells and depths to water summaries, RCC has not determined other well attributes such as the specific age of monitoring