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s <br /> r • <br /> Messers Trommer and Larson <br /> Re:Annual Five-Year Review Various sites <br /> Page 2 of 2 Page 2 <br /> 19,d� 08 June 2009 <br /> � )-b <br /> well MW-3 a <br /> ppears to have rebounded from 790 ug/L and 2.5 Ng/L to 86000 ug/L and 270 <br /> Pg/L, respectively. Concentrations of the same analytes in MW-7 are also, elevated at 2,100 t <br /> Pg/L and 230 Ng/L respectively. Impacted ground water around MW-3 is delineated by <br /> monitoring wells in three directions while it is similarly delineated in only one direction around <br /> MW-7. The impacted groundwater is in an area of high groundwater usage, in fact MW-7 is <br /> approximately 15 feet from a domestic well believed to be only 140 feet deep. <br /> In August 2008, an MIP invlestigation in the core areas was conducted, but the results have not <br /> been submitted to the EHD for review. At this time the EHD believes additional monitoring of the <br /> core and inboard wells is warranted to more fully understand the import of the recently reported <br /> monitoring results, quarterly monitoring of MW-3 and MW-7 would also be helpful. The EHD <br /> also believes it would only be prudent to review the report of findings for the recent MIP <br /> investigation before making or concurring with a closure recommendation. The EHD would <br /> appreciate your reconsideration of the closure recommendation on this site at this time. <br /> 15 E. Grant Line Road — Your draft letter recommends site closure consideration. The EHD <br /> believes the site is nearly ready for closure consideration but has been seeking to have the <br /> vertical delineation of the plume of impacted groundwater completed and the down-gradient <br /> extent confirmed. The EHD has approved installation of monitoring wells to delineate the vertical <br /> extent based on significant hits in a cone penetration testing (CPT) investigation on site and in <br /> grab samples collected offsite in the down-gradient direction. The EHD has reevaluated the <br /> approved scope of work and reinterpreted the TPHg plume history on the site and now believes <br /> new grab groundwater samples will be sufficient to conclude the issue. The EHD plans to issue <br /> a directive rescinding the approval for the additional monitoring wells and recommending the <br /> acquisition of grab groundwater samples to complete the delineation requirements for site <br /> closure consideration. The EHD would appreciate your reconsideration of a site closure <br /> recommendation at this time. <br /> 2315 N. California Street—Your draft letter repeats last year's recommendation for site closure <br /> consideration. Two additional groundwater monitoring wells have been installed to complete the <br /> lateral delineation of impacted groundwater. The three sampling events conducted to date have <br /> yielded no quantifiable detections of <br /> have an additional monitoring evcontaminants of concern, although the EHD would prefer to <br /> recommending site closure considerent on these new wells, the EHD will proceed with <br /> report. ation and requesting submission of a site closure summary <br /> If you need more information to complete your review of these sites, contact Nuel Henderson, <br /> Engineering Geologist, at (209) 468-3436 or by mail (address on the letterhead). <br /> Nuel C. Henderson, Jr., PG <br /> Engineering Geologist <br /> C: Jim Barton, PG, CVRWQCB, 11020 Sun Center Dr. #200, Rancho Cordova, CA 95670 <br /> S-Year Review Comment Letter 0609.doe <br />