SITE INFORMATION AND CORRESPONDENCE

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The MRP required continued monitoring ofgroundwater on a quarterly basis. Results ofthe Phase ll Investigation were provided to the RWQCB in a combined Remedial Investigation/Fourth Quarter 1997 Groundwater Monitoring Report dated February 4, 1998. A shallow aquifer pump test was conducted in August 1998 and groundwater monitoring was continued quarterly through 1998. The pump test and groundwater monitoring results were provided to the RWQCB in the 1998 and First Quarter 1999 Groundwater Monitoring Report, dated May 14, 1999 (IT, 1999). Groundwater monitoring, conducted by IT, continued for three quarters in 1999 the results for which were presented in the Quarterly Monitoring Report for June, August,and November 1999, dated January 20, 2000 (IT, 2000). A meeting between the client (Cal Farm Bankruptcy Trust), the former consultant (IT), and the RWQCB was held on June 8, 1999. Among the items discussed were factors and obstacles related to the bankruptcy status of the site, issues regarding groundwater gradient, issues regarding the severe seasonal ponding at the site, issues regarding neighboring sites, reduced monitoring frequency for specific constituents,and remedial options. Contributions of nitrate from off-site sources in the south and the north were discussed, and a tentative agreement was made that Cal Farm was only responsible for the area of the warehouse and fenced yard. The pump test results indicated that the shallow aquifer could not support traditional pump and treat methods and that other forms of remediation should be investigated. Phytoremediation and makeup source water were two alternatives discussed. The Cal Farm bankruptcy trust was directed by the RWQCB to prepare a remedial options report/feasibility study. IT prepared an outline,which was submitted in July, 1999 to wait funding from the bankruptcy court. IT continued groundwater monitoring through 1999,and was unable to continue monitoring through the year 2000 due to lack of funding from the court. Shortly following the January 2000 Groundwater Monitoring Report(IT,2000),the bankruptcy was resolved. The property was split into four parcels. Mr. Arnold Hof, the former tenant leasing the parcel containing the warehouse and fenced sales yard, bought the parcel and assumed the responsibilities for groundwater monitoring at the site. In 2002, Mr. Hof contracted with HydroGeoLogic Inc. (HydroGeoLogic) to perform two rounds of groundwater monitoring (HydroGeoLogic, 2002 and 2003). Based on the April and October 2002 results and recommendations (HydroGeoLogic, 2002 and 2003), a revised Draft MRP dated April 30, 2003 was issued by the RWQCB (RWQCB, 2003). Based on the overall declining trends of chemicals of concern, the RWQCB concurred that a reduction in monitoring frequency to annual events and a reduction in the analytical program were both warranted. The revised Draft MRP also called for the abandonment of two wells, MW-8 and MW-9, documentation of phytoremediation activities, and a replacement well for former MW-6, which had been inadvertently destroyed sometime following the March 1999 sampling event. In February 2004, the RWQCB (RWQCB, 2004a) issued a letter informing Mr. Hof of delinquent reports for 2003, and that a first quarter 2004 sampling event was required,in addition to the annual third quarter event for 2004. The RWQCB also stated that a replacement well for MW-6 would not be required of Mr. Hof. In the field south of the warehouse,Mr. Hof had planted three consecutive crops of Safflower(known for its deep roots and strong uptake of shallow groundwater) in 2001, 2002, and 2003, but was unable to do so in 2004 due to an extremely dry Spring season. ca1&.4m11 2 ms�wc« AWQ12rmi