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' Fmr. Unocal • - 2 - • 21 December 2007 1 Fmr' Montgomery Wards 5400-5606 Pacific St., Stockton tComments: The Workplan is sufficient for the proposed.work. However, there is no detailed discussion in the Workplan of how ENSR and CEMC came to the conclusion that the existing AS/SVE system was inadequate (the evaluation), nor was the technical data provided of the individual ' well testing that was done to reach that conclusion. Nevertheless, I do appreciate the time and effort that ENSR and CEMC put into the Workplan; and I will concur with it when the following conditions are met: ' It is my understanding from previous conversations with ENSR that there is a question whether the treatment system could adequately affect the groundwater plume to the ' north under Robinhood Drive. Please submit a lettgr addendum to the Workplan, which provides a detailed explanation of the existing SVEJ'AS system testing procedures, conipares the"testing results to the expected pe4ormance specifications for a`similar ' designed system, and shows that the entire groundwater plume will be addressed by the proposed upgrades. In other words, the technical justification for replacing all, or a portion of, the existing system needs to presented in'a manner thatthe State Water ! ' Resources Control Board, Underground Storage Tanks Cleanup Fund and Regional Board staffs can concur to"ENSR's and CEMC's determination that the upgrades are necessary and appropriate. ' The Workplan does not include labeled geologic cross sectional views of the remediation well construction and the lithological sequence to be remediated. Submit two geologic cross sections oriented as an "X" (at right angles), and include the proposed remediation wells, along with the existing remediation and monitoring wells, within the lithology of the remediated zones. ' Revise the map or plan view to include the lines of above cross sections indicated as an "X "on Attachment B Figure 2 (attached). Submit a tentative schedule with dates for the proposed fieldwork and reports, so that I ' may input the proposed work into GeoTracker as milestones to be completed. Add Regional Board staff to the list of recipients for the well installation activities report. ' Appendix B, Section 4.0 Schedule currently lists only the California Department of Water Resources and the San Joaquin County Environmental Health Department (SJCEHD) as recipients of that report. All reports are to be submitted in paper copy to tthis office, as well as electronically to GeoTracker (Appendix B Section 3.6). • Give the SJCEHD and myself at least 3 working days notice for start of fieldwork. 1 i , 1