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New West Petroleum #1003 • 2 - • 6 February 2008 Lodi, San Joaquin County treatment extraction well to improve hydraulic control of the MTBE groundwater plume and to prevent MTBE impacts to a nearby municipal supply well (San Joaquin County Service Area 31 , Well 2). The PAR states that designing and acquiring access for offsite treatment may take up to nine months, and recommends accelerating the CAO process to exceed the schedule requirements of the CAO. To that end, the PAR recommends submittal of a Corrective Action Plan (CAP) to serve as the functional equivalent of the CAO-required Feasibility Study (FS), due 18 April 2008, and Final Remediation Plan (FRP), due 1 August 2008. Comments: 1) The PAR fulfills the CAO requirement in Order No. 10, and is accepted. 2) 1 concur that interim GWP&T is effective in reducing groundwater concentrations on site, and when properly designed and site conditions are favorable, is a proven technology effective in reducing petroleum hydrocarbon contaminant mass while providing protection to sensitive receptors through hydraulic control of an aquifer. 3) Please note that the CAO time schedule is the maximum time allowed for each ordered task, and that efforts to accelerate the remediation schedule are acceptable to this agency. However, the FS and FRP, or the proposed functionally equivalent document to the FS/FRP (CAP) document(s) must include at a minimum, the information necessary to determine whether the proposed remediation is technically feasible and cost effective, and the remedial action will move the project towards closure in a reasonable time frame. CAO, Order No. 12 requires "By 18 April 2008, submit a Feasibility Study that provides a summary of remedial alternatives evaluated to address applicable cleanup levels for the affected or threatened human health and/or waters of the State. The Feasibility Study shall propose at least two remedial technologies that have a substantial likelihood to achieve cleanup of all impacted soils and groundwater and shall include a schedule for achieving cleanup. The remedial technologies must be evaluated with respect to their ability to be implemented, cost, and effectiveness. The Feasibility Study shall include the rationale for selecting the preferred remedial alternative. The Discharger shall attempt to clean up each constituent to background concentrations, or to the lowest level that is technically and economically achievable and which complies with all applicable WQOs of the Basin Plan and promulgated water quality criteria." CAO, Order No. 13 requires "The Feasibility Study shall evaluate remedial options to prevent MtBE and other petroleum hydrocarbon impacts to CSA-31 Well 1 and Well 2." CAO, Order No. 15 requires "Within 90 days of Water Board staff concurrence with the proposed remedial action described in the Feasibility Study but no later than 1 August 2008, submit a Final Remedial Plan (FRP). The FRP must include a detailed description of the remedial actions to address cleanup of the entire groundwater plume and source area soils. The FRP shall also include a schedule to implement all remedial