SITE INFORMATION AND CORRESPONDENCE

Home Browse Search

New West Petroleum #1003 2 - Lodi, San Joaquin County. 28 May 2008 states that "The 4th Quarterly Report of each year shall be an Annual Report submitted to the Regional Board by 1 February of each year. This report shall contain an evaluation of the effectiveness and progress of the investigation and remediation..." Since the Annual Report provides a summary and evaluation of the previous year's activities, including "...if desired, a proposal and rationale for any revisions to the groundwater sampling plan frequency and/or list of analytes..."annual sampling and reporting will continue to be conducted during the fourth quarter of each calendar year. Please include future requests for changes to the MRP sampling plan frequency and/or list of analytes with a rationale for the changes in the fourth quarter Annual Report. 3. Summarized from Request Table 1, the above proposed bullets three and four provide schedules for MW-2, MW-5A, and MW-5B that contradict each other by requesting semiannual sampling for all analyses in bullet three versus a combination of quarterly and annual sampling for specific analyses in bullet four. Since the intent of the Request appears to be that MW-2, MW-5A, and MW-5B are sampled semi-annually and a specific rationale is given for semi-annual sampling of those wells in Request Table 1, MW-2, MW-5A, and MW-56 are removed from bullet four's schedule and will be analyzed for all constituents on a semi-annual schedule. 4. The MRP also states "The Dischargers shall not implement any changes to this MRP ... until Regional Board staff approve those changes in writing." The approved changes to the MRP are listed in the new MRP Table 1 below: TABLE 1 SAMPLING FREQUENCY Quarterl Semi-Annuall Annuall Wells EW-1 EW-2 EW-3 MW-2, MW-5A, MW-1 , EW-1 EW-2 EW-4 EW-5 MW-3A MW-56 EW-3 EW-4 EW-5 MW-36 MW-4A MW-3A MW-313 MW-4A MW-4B MW-4C MW-4B MW-4C MW- MW-6B MW-6C 6B MW-6C MW-7A MW-7A MW-7B MW-7B MW-8A MW-8B MW-8A MW-8B MW-9B MW-9C MW-9B MW-9C MW-9D CSA-31 Well 1 MW-9D CSA-31 Well and CSA-31 Well 2 1 and CSA-31 Well 2 New WellS5 1 All wells will be monitored quarterly for water levels, and the presence and thickness of free product. 2 All constituents with the exception of Total Petroleum Hydrocarbons as gasoline(TPHg)and BTEX. See exception 5 below for new wells. 3 All constituents in the second and fourth quarters of the calendar year. 4 Add TPHg and BTEX(analyze all constituents)during the fourth quarter of the calendar year. See exception 6 below for MW-1. 5 Any new monitoring or treatment wells added to this program will initially be sampled on a quarterly basis for all constituents listed in the MRP for a period of at least one year,after which a request for reduction in sampling those well may be submitted with the rationale for the proposed changes in the fourth quarter annual report. Sample collection and analysis for new wells shall follow standard EPA protocol. 6 MW-i.sampled for all constituents only annually during the fourth quarter of the calendar year.