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AZURE ENVIRONMENTAL March 4, 1996 Harlan Knoll San Joaquin County Public Health Services R C E I �� 445 N. San Joaquin Street 4� Stockton, California 95201 MAR 0 61996 RE: Manna Pro Corporation Facility ENVIHvN w EN_IAL Ht_Ai_' 4004 South El Dorado, Stockton, California PERMIT i SERVICE,--- Dear ERA,ICE„Dear Mr, Knoll: This letter is to confirm our conversation on February 13, 1996, regarding submittal of a revised Corrective Action Plan (CAP) and modifications to the ground-water monitoring schedule for the Manna Pro Corporation facility in Stockton, Corrective Action .Plan As we discussed, Azure Environmental will develop a revised Corrective Action Plan (CAP) that will supersede the plan developed by GTI dated July 15, 1994. The revised CAP will include review of the Site investigation and monitoring data in light of recent regulatory directives promulgated by the State Water Resources Control Board. Our initial evaluation of Site data indicates soil and ground water have been adequately characterized, the petroleum hydrocarbon plume in Site ground water has stabilized, and petroleum hydrocarbon concentrations in Site monitoring wells are generally decreasing. The Site appears to represent a low risk ground water case since nearby water supply wells, deeper drinking water aquifers and other sensitive receptors are not likely to be impacted. Therefore, Azure plans to develop a revised Corrective Action Plan that considers the technical and economic feasibility of other remedial alternatives, including a natural attenuation and biodegradation alternative. Azure's schedule for completion of the revised CAP will follow the adoption of revised guidelines for petroleum hydrocarbon cases at the State and County levels, which is anticipated to be completed in mid- to late-1996. Ground-Water Monitoring Program In the interim period, Azure will perform ground-water monitoring activities at the Site. The objectives of the revised ground-water monitoring program are to obtain the necessary data for assessing changes and trends in petroleum hydrocarbon concentrations and evaluating criteria for Site closure. Following our review of the more than four years of quarterly monitoring data collected at the Site, we have developed a modified schedule for monitoring during the 1996 annual period, The revised program will focus on continuing to collect quarterly data from downgradient wells of concern, while reducing the frequency of monitoring the near-source and crossgradient wells. Future monitoring results will be reviewed to assess further reductions in the scope of the monitoring program. 828 Mission Avenue, San Rafael, CA 94901 0 4151485-9740 Fax 4151485-6062