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Gene Gabbard Page 2 of 3 <br /> Jim and Sheyla Creel <br /> 640 N. El Dorado Street <br /> 4. It must be demonstrated that the contaminant mass remaining onsite is <br /> undergoing natural attenuation, and an estimate of the time required until <br /> background levels are reached must be provided; <br /> 5. The closure criteria presented in Appendix A of the Tri-Regional Guidelines <br /> must be satisfied; and <br /> 6. The potential for vapor intrusion of the residual contaminants into the onsite <br /> structure must be evaluated using the San Francisco Bay Regional Board <br /> Environmental Screening Levels (ESL). <br /> After the meeting it was the understanding of the SJC/EHD that a report addressing the <br /> above listed concerns, and/or a work plan to obtain any additional data necessary to <br /> complete such a report, would be submitted by your consultant, but neither a report nor <br /> a work plan has been received by this agency. It was also noted at the meeting and in <br /> the letter that lack of reimbursement from the State Cleanup Fund is not a justification for <br /> site closure. <br /> You are still under directive to monitor and report quarterly on the contaminant <br /> concentration trends in groundwater impacted by the unauthorized waste oil UST <br /> release on your site. You are currently out of compliance for discontinuing routine <br /> monitoring and reporting. The last report SJC/EHD has received, and that was <br /> submitted to Geotracker, the State Water Resources Control Board database website, <br /> was submitted in August 2006. The SJC/EHD is modifying your monitoring <br /> requirements as follows: <br /> 1. Reinitiate monitoring by gauging depth to water and properly sampling wells MW- <br /> 1, MW-2, MW-3 and MW-4; <br /> 2. With the exception of chlorinated solvents, analyze the MW-3 sample according <br /> to the current analytical regimen and for total petroleum hydrocarbons quantified <br /> as motor oil (TPH-mo), as kerosene (TPH-k) and as oil and grease (TPH-og); <br /> 3. Analyze the groundwater samples collected from monitoring wells MW-1, MW-2 <br /> and MW-4 for any TPH analytes detected in the MW-3 sample. The method <br /> detection limit for the analyses for each sample should be approximately 50 to <br /> 100 micrograms per liter if there is no detection of the analyte; and <br /> 4. If the outlying wells do not have detectable concentrations of hydrocarbons after <br /> the first testing, sample and analyze only MW-3 and the down-gradient <br /> monitoring well each succeeding monitoring event for TPH analytes detected in <br /> the initial MW-3 sample collected at the resumption of groundwater monitoring. <br /> You are directed to immediately resume routine quarterly groundwater monitoring as <br /> modified above and to submit the overdue report or work plan. The report is due for <br /> submittal no later than February 15, 2008. Also, you are directed to reinitiate extraction <br /> and monitoring of free product associated with monitoring well MW-3 and report <br /> quarterly on the extraction progress and results. <br /> In the FUND's Final Decision, dated 03 October 2006, Ms. Evoy stated her concern that <br /> the construction of monitoring wells MW-3 is providing a vertical conduit for free product <br /> in the fine-grained vadose zone to migrate to groundwater. This hypothesis would <br /> account for the lack of free product in the down-gradient wells. Provide the SJC/EHD <br />