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1 <br /> SECTION 4 <br /> RESPONSE TO LETTER FROM THE <br /> COUNTY <br /> 1 <br /> In this section, ERM and Safeway address the concerns of the <br /> County, as expressed in the letter to Safeway dated May 14, 1992 <br /> (Appendix C) <br /> • The site lacks a well upgradient of the former underground <br /> storage tank (UST) location <br /> The three monitoring wells (MW-1, MW-2, and MW-3) that were <br /> closed in November 1991 were considered to be upgradient <br /> Analytical results illustrated in Figures 2-4, 2-5, and 2-6 indicate <br /> that the area affected is south of the former tank locations, which <br /> is consistent with the flow direction established. While <br /> groundwater movement has no doubt been altered by prolonged <br /> drought and increased pumping throughout the area, <br /> groundwater movement has been steady for at least the past two <br /> years Should the direction of groundwater movement begin to <br /> change in a significant manner, we would agree that another <br /> well may be advisable <br /> IThe County correctly states that no detailed investigation of the <br /> soils or groundwater below the UST pipeline has been done At <br /> this time, however, additional data regarding soils beneath the <br /> pipeline is not critical to understanding site conditions Also, a <br /> well along the fuel lines would be considered upgradient and, as <br /> previously discussed, is not crucial to the current monitoring <br /> • Diesel-contaminated soil poses a threat to water quality <br /> Elevated concentrations of TPH-diesel in the soil have been <br /> identified on the Safeway property and below Navy Drive to the <br /> south The soil in question is found a minimum depth of 25 feet <br /> below grade <br /> Well sampling has shown that groundwater has not been <br /> significantly affected. It should be emphasized that HydroPunch <br /> data, used primarily as a screening tool, often yields elevated <br /> analytical results that are not duplicated in well samples <br /> Analyses of the HydroPunch sample from boring B-21 in <br /> November 1991, for example, showed a concentration of 6 9 mg/kg <br /> of TPH-diesel Boring B-21 was converted into monitoring well <br /> I 4-1 <br />