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0 &Ineefflcke-Recon <br /> ENGINEERS,HVDROGEOLOGISTS B APPLIED SCIENTISTS <br /> We acknowledge the RWQCB's position that the SDCDs are to obtain approval from the RWQCB <br /> before the installation or destruction of any monitoring well in advance of field work. As <br /> previously stated, the SDCDs did receive approval for the abandonment procedures from the San <br /> Joaquin County Public Health Services, Environmental Health Division, through the permitting <br /> process. In addition, all other well installations were approved verbally or in writing by the <br /> RWQCB. <br /> PROPOSED PHASE I INTERIM REMEDIAL ACTION DETAILED PLAN (31 OCTOBER <br /> 1997) <br /> 1. The plan is well documented and very detailed.The SDCDs propose to install 17 groundwater extraction wells and 34 <br /> piezometers in a line parallel to Pacific Avenue. Groundwater will be extracted and treated by air stripping followed by <br /> liquid-phase granular activated carbon. Treated groundwater will be discharged to the storm drain under an NPDES <br /> permit. The plan is hereby approved. <br /> We appreciate the RWQCB's approval of the Proposed Phase I IRA Detailed Plan. As we <br /> discussed with Ms. Wyels on December 2, 1997, LFR has been working with Lincoln Properties, <br /> Ltd. (LPL) to address LPL's concerns regarding certain technical issues regarding the Phase I IRA <br /> design. LFR and LPL discussed LPL's preliminary comments to the Proposed Phase I IRA <br /> Detailed Plan during a conference call on November 20, 1997, during our meet-and-confer session <br /> on December 3, 1997, and during a follow-up conference call on December 10, 1997. We <br /> discussed LPL's comments and the results of these discussions with Ms. Wyels on December 3, <br /> 1997, and briefly with Ms. Wendy Cohen on December 16, 1997. We will provide the RWQCB <br /> with our responses to LPL's comments to the Proposed Phase I IRA Detailed Plan, along with our <br /> proposed revisions to the Proposed Phase I IRA Detailed Plan for the RWQCB's approval on <br /> January 16, 1998. <br /> 2. LFR states that well MW-102 will not be added to the quarterly monitoring program.This sort of decision may only be <br /> made in consultation with staff. Unless discussed further, well MW-102 is to be included in the quarterly monitoring <br /> events. <br /> Based on a review of the well construction data and historical water-level data collected from <br /> wells MW-11, MW-100, MW-101, and MW-102, the SDCDs recommend adding MW-101 to the <br /> quarterly monitoring program in place of MW-11. Well MW-101 is located approximately 12 feet <br /> upgradient and 25 feet away from MW-11, while MW-102 is approximately 50 feet upgradient <br /> and 60 feet from MW-11. Well MW-11 is screened across the interval 50 to 70 feet bgs. MW-101 <br /> is screened across the depth interval 40 to 75 feet bgs, which LFR believes, is more representative <br /> of A-zone aquifer conditions than MW-11. Although MW-102 is screened across the depth <br /> interval 45 to 75 feet bgs and is also representative of the A-zone aquifer condition, water-level <br /> data collected from MW-102 do not follow the trend that is observed in other A-zone monitoring <br /> wells. Water-level data collected from MW-102 have not been used to prepare water-level <br /> elevation maps. We will continue to measure water levels in MW-11, and in wells MW-100 and <br /> MW-102, on a quarterly basis. The Quarterly Monitoring Plan for the project will be revised to <br /> reflect this modification and will be submitted to the RWQCB for approval. <br /> Llr-Resp-RWQCB-Dec97-04111:SRL 7 <br />