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Mr Mark Adams. Trustee - 2 - 20 April 2009 <br /> Lincoln Center Environmental-!mediation Trust �J <br /> Point Richmond, CA <br /> including costs, of these reports shall bear a reasonable relationship to the need for the report and the <br /> benefits to be obtained from the reports... The additional cost to Chevron for new monitoring wells has <br /> not been shown to be necessary or justified based on evaluation of all data previously collected for the <br /> petroleum hydrocarbon release.- In fact, only the Trust would stand to benefit from Chevron's installation <br /> of new wells, since the Comments comment #2 requests Chevron transfer wells MW-2, MW-3, MW-5, <br /> and MW-8 to the Trust for invetstibafion of their chlorinated solvent groundwater plume. <br /> % # , i, <br /> Comment #2: In addition.to'xhe�dhevron,monitoring well transfer request described above, the Trust <br /> states their concern that Trust extraction wells (GEW-0228. GEW-008A and GEW-007A) should not be <br /> included in the Chevron wells abandonment prior to closure. <br /> Response: Prior to well abandonment, Chevron is encouraged to transfer ownership and liability for the <br /> above requested monitoring wells to the Trust for the chlorinated solvent plume investigation, and to <br /> provide reasonable access for the Trust sampling and eventual abandonment of those wells by the <br /> Trust. The Comments statement to ensure the Trust's extraction wells on the Site are not included in <br /> Chevron's wells abandonment is unusual, since Regional Board staff in this program have not (and will <br /> not) directed Chevron to abandon the Trust's extraction wells. Nevertheless, when the well <br /> abandonment approval is given to Chevron, staff will add the requirement that only Chevron's wells are <br /> to be abandoned, unless other arrangements are made between Chevron and the Trust, and that the <br /> Trust extraction wells are to be properly protected during the Chevron wells abandonment. If the Trust <br /> would like to have/use any of Chevron's wells for their case, we recommend that the issue be resolved <br /> between the Trust and Chevron as soon as possible. <br /> The final Comments statement "I believe that further investigation and continued monitoring by Chevron <br /> will further the Trust's mission", while revealing the purpose for the Trust opposition to closure for <br /> Chevron, does not stand the test of CWC Section 13267 (b) (1) as described above. The Trust mission <br /> statement is not justified by the petroleum hydrocarbons data, nor is it relevant to Chevron's closure <br /> request Likewise. the Comments do not provide adequate or reasonable technical justification for <br /> reinstalling the wells and continued monitoring by Chevron. Staff finds the existing data adequately <br /> support Chevron's closure request, <br /> if you have any questions, you may contact me at (916) 464-4615 or by e-mail at the following address <br /> }barton@waterboards.ca.gov. <br /> JAMES L.L. BARTON. P G <br /> Engineering Geologist <br /> UST Enforcement Unit 2 <br /> cc Mr. Patrick Pulupa, SWRCB Office of Chief Counsel, Sacramento <br /> Mr. Mark Owens, SWRCB UST Cleanup Fund, Sacramento <br /> Mr, Michael Infurna, San Joaquin County Environmental Health Division, Stockton <br /> Ms. Stephanie Furgal, Chevron Environmental Management Company, <br /> 6111 Bollinger Canyon Rd., San Ramon 94583 <br /> Mr. Phil Johnson, Sims-Group Management, 374 Lincoln Center, Stockton 95207 <br /> Mr. David Lay, Arcadis. 950 Glenn Drive, Ste. 125. Folsom 95630 <br />