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Mr. Kahled Anber - 2 - 21 April 2008 4040 E. Main St., Stockton, San Joaquin County From 2005 to 2007, groundwater flow direction varied from northeast to east, and the groundwater elevation had risen nine feet to approximately 57 feet bgs, submerging the tops of the well screens under three feet of water. In the Quarterly Report-First Quarter 2007 (Report), the maximum groundwater concentrations reported were TPHg, 300 ug/L; MtBE, 29 ug/L; 1 , 2-DCA, 150 ug/L; and ethylene dibromide (EDB), 2.1 ug/L. The Report recommended continuing quarterly monitoring, removing TPHd from the list of groundwater analyses, and conducting further site assessment of the vertical and lateral extent of the groundwater plume onsite and offsite. In August of 2007, AGE notified the SJCEHD that they were holding the first and second quarter 2007 monitoring reports and cancelling the third quarter monitoring event due to non- payment of bills. On 11 September 2007, the SJCEHD issued written notice that the site would be transferred to the Regional Board if quarterly monitoring did not resume, and if the past due reports and a workplan to investigate the petroleum hydrocarbons plume were not received within 14 days. The SJEHD reiterated these directives in a letter dated 5 February 2008. To date, none of the required submittals have been made and quarterly monitoring has not resumed. I have conducted a preliminary case review and agree with the previous directions given by SJCEHD. Therefore, you are to comply with all SJCEHD directives given to date, including but not limited to: • Submit a workplan for an additional investigation to delineate the lateral and vertical extent of the petroleum hydrocarbon release to soil and groundwater, and all past due monitoring reports held by AGE, by 1 June 2008. A report of the soil and groundwater investigation, due 1 September 2008, shall provide conclusions and recommendations for additional investigation or remediation, if warranted. • Resume routine quarterly monitoring of all monitoring wells starting with the second quarter of 2008. All monitoring reports are due the last day of the first month following the sampling quarter (i.e., the second quarter [April, May, June] 2008 report is due in our office in paper copy by 31 July 2008). In the monitoring reports your consultant shall provide a justification that, although groundwater is currently above the screened intervals of all wells, the manner in which the samples are taken facilitates the collection of representative groundwater samples and the analytical results are valid. • Submit all documents (workplans and reports) and data in electronic format to Geotracker as required by the State Water Resources Control Board, and in paper copy to this office, by the due dates listed above and by all subsequent due dates established by Regional Board staff directives. • All documents must conform to the Regional Board staff guidance outlined in Appendix A Reports, Tri - Regional Board Staff Recommendations for Preliminary Investigations and Evaluation of Underground Tank Sites, dated 16 April 2004, which can be electronically downloaded from: http://www.waterboards.ca.gov/centraIvalley/water_issues/underground_storage_tanks/