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DBrusea Associates, Inc. h nviroaammud Enginmring Brusca Associates, Inc. 1860 Sierra Gardens Drive, #332 Roseville, CA 95661 Phone (916) 677-1470 Fax (916) 677-1471 BruscaAssociates.com From: Robert McClellon [EH] [mailto:RMcClellon@sicehd.com] Sent: Monday, October 30, 2017 3:04 PM To: Joe Brusca <ibrusca@bruscaassociates.com> Subject: RE: Murphy Parkway Lathrop Soil Gas Monitoring Workplan Joe, just quickly looking over the plan there are a couple things I see right off that will need to change. The depth of waste was 19 feet. The probes need to extend to the depth of waste (see T27CCR 20925 - below). They should be double completion (see below under c. depth). Monitoring should be monthly first year (summa canister). Then re-evaluate the situation. So if you could amend the plan and provide a permit for installation and H&S Plan. We can get started. I know initially I spoke about quarterly sampling for 1 year. I was corrected by CalRecycle staff. Robert Section 20925. CIWMB - Perimeter Monitoring Network. (a) Location (1) Perimeter subsurface monitoring wells shall be installed around the waste disposal footprint but not within refuse. In some cases the installation of monitoring wells may not be necessary around the entire perimeter of the disposal site permitted facility boundary. In such a case, the operator shall demonstrate to the satisfaction of the EA that landfill gas migration could not occur due to geologic barriers and that no inhabitable structure or other property or land use, such as agricultural lands, within 1,000 feet of the disposal site permitted facility boundary is threatened by landfill gas migration. (2) Perimeter monitoring wells shall be located at or near the disposal site permitted facility boundary. The operator may establish an alternate boundary closer to the waste disposal footprint based on a knowledge of the site factors in Section 20923(a)(2). When compliance levels are exceeded at the alternate boundary, the operator shall install additional monitoring wells closer to the permitted facility boundary, pursuant to Section 20937. (b) Spacing (1) The lateral spacing between adjacent monitoring wells shall not exceed 1,000 feet unless the operator demonstrates to the satisfaction of the EA and CIWMB, based on the factors specified in Section 20923(a) (2), that there is no potential for adverse impacts on the public health and safety and the environment from such wider spacing. (2) The spacing of monitoring wells shall be determined based upon, but not limited to: the nature of the structure to be protected and its proximity to the refuse. Wells shall be spaced to align with gas permeable structural or stratigraphic