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'll R ' jU8,11| Water Quality CV0tro^ .}a rd — <br /> Ceniru1 \/ul!uy Region <br /> ~=~ k^,| L h""u/n..S,u. , �' chx" <br /> `,,,"wm*m^ioom* �m"u <br /> /m..,'."1 x:111c^^. °d", . <br /> /:w464-.�2"/ / urx.'41�-4e` <br /> m* """"um^�°.,p"`'m"^a1 . <br /> Apri| 27. 2007 <br /> Mr. Dennis Zaragoza. Esq. <br /> Attorney at L8Vv <br /> P (). Box 2100 <br /> San Francinno, CA 84120'2190 <br /> REVIEW OF PROPOSED WELL 3A/NPL/NG PROGRAM AND PROPOSED ADDITIONAL <br /> DEEP MON/TOR/NG WELL, FORMER BUSY BEE CLEA0ERS, 40 NORTH MAIN STREET, <br /> LDD/, 34N JOAC)U/W COUNTY' <br /> Staff of the California Regional VVGt8[ Quality Control Bo@rd, Central Valley Region (Regional <br /> Water Board) has reviewed the Proposed Well 38rnp&7g Program and Proposed Additional <br /> Deep Groundwater Monitoring Well for the Former Busy Bee Cleaners (the Site), 40 North <br /> Main Street. Lodi, San Joaquin County- The letter is dated March 22. 2007. and was received <br /> by the Regional VV8te[ Board On KA8[oh 27, 2007 Your environmental consultant. E2C <br /> Remediation. Inc.. of Bakersfield prepared the letter On behalf of the representatives of the <br /> Busy Bee Site and the City of Lodi. <br /> The purpose Of this letter is to present the tentative agreements reached in o November 3, <br /> 2006 nle8dnQ between the representatives of the' Busy Bee Site and the City of Lodi. propose . <br /> modifications to the nornp|iDg prOg[G[D as jointly developed by the representatives of the Busy <br /> Bee Site and the City of Lodi, and propose one additional deep monitoring well. <br /> The Regional VV818r B0@/d'COnCU[S with the proposal to install one additional deep monitoring <br /> well, and with the p[0pOS9d location. A#8[ four quarters of nlODitO[iDg data are obtained and <br /> evaluated from the new deep well, a determination can be made if continued quarterly <br /> monitoring data is Deed8d. Or if monitoring frequency Can be reduced to semiannual. <br /> The Regional VVat8[ Board has the following CO[nnnentS On the proposed modifications to Nn <br /> existing groundwater monitoring well S3Dlp|iDg program. FirS[. Staff request clarification <br /> concerning the proposed frequency Of monitoring for DVV'31313. In the t8XL this well is <br /> recommended for annual sampling. though Figure 1 ha's the semi-annual symbol a3SoCiG18d <br /> with this well. Second, staff finds that DVV'3BB should be sampled on a semi-annual basis. <br /> We believe that one deep well beneath the |0vver portion Of the 6h8UOvv plume should be <br /> monitored semi-annually. like it is recommended to sample OVV'1BB semi-annually to monitor <br /> the deep zone beneath the upper portion of the ShaUOvv plume. Thind. Staff recommends that <br /> k8\&-15BB and MVV'17BB be monitored On a semi-annual basis instead of the proposed <br /> annual sampling, Our concern is that an annual check is not aufUc/ent at the present time to <br /> monitor the down-gradient |8t8r8| S/t[ennhieS of the existing plume. Once the soil vapor <br /> extraction combined with groundwater air Sp8ng}ng nsrn8dy is irnp|8[n8nt8d, then the p,OpuS8| <br /> to monitor MVV'15BB and M\8-17BB onnoa|k/ can be reevaluated. <br /> [oIV�)rn/x Environmental Protection Ageng` <br />