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page 2, 7500 Eleventh Street The report recommends three additional rounds of groundwater sampling and analysis, and if results reveal no unexpected changes in the plume characteristics, that the site should ,be considered for closure. PHS/EHD does not agree with this recommendation. The levels of MtBE at this site preclude any consideration for closure prior to a complete investigation of the extent of the plume, followed by remediation of the contamination. California Code of Regulations Title 23, Division 3, Chapter 16, Article 11 lists the necessary steps in the investigation and cleanup of contaminated underground storage tank sites. Following completion of the investigation of the lateral and vertical extent of the contamination, a feasibility study must be conducted to evaluate alternatives for remediation or mitigation of the actual or potential adverse effects of the unauthorized release. These alternatives must be evaluated for cost-effectiveness, and the responsible party shall propose to implement the most cost-effective corrective action. As the responsible party to this site you have previously been directed that quarterly groundwater monitoring and sampling shall continue at this site until otherwise directed by PHSIEHD. A work plan to continue the investigation of the vertical and lateral extent 01 f The the contaminant plume at this site'is due to be submitted to PHSIEHD by August 20, work plan should include a proposal to install a monitoring well on the southern portion of the property, to verify the possibility of an offsite source of groundwater contamination. If you have any questions please call Lori Duncan at (209) 468-0337. Donna Heran, REHS, Director Environmental Health Division Dot Lofstrom R. G. Lori Duncan, Senior REHS Engineering Geologist li LOP/Site Mitigation Unit IV 1 cc: Marty Hartzell, CVRWQCB Dai Watkins, SJC i s s I I _