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Second Semi-Annual 2021 Groundwater Monitoring, Batch Extraction Results Report & Supplemental Site Investigation <br />Waterloo Food and Fuel <br />3032 East Waterloo Road, Stockton, California <br />Page 5 <br />MODIFICATIONS FROM STANDARD MONITORING PROGRAM <br />On August 4, 2021, the Central Valley Regional Valley Water Quality Control Board (CVRWQCB) <br />issued a letter responding to a review of the Apex First Semi-Annual 2021 Groundwater Monitoring <br />Report for the Site dated June 15, 2021 (1Q21 GMR) and a review of the Apex Underground <br />Storage Tank System Leak Investigation Report of Findings (UST Report), dated June 14, 2021. In <br />summary, the CVRWCB provided the following six (6) comments: <br />Please sample all Site monitoring wells deemed functional in the 1Q21 GMR, as well as <br />remedial wells EW-1 through EW-3 during the 3rd quarter 2021 and submit a groundwater <br />monitoring report by 1 November 2021. In this report, and all subsequent GMRs, please <br />include Site free product data, including measured depth to product and product thickness, in <br />the current and historical groundwater data tables. Additionally, as part of the GMR, please <br />include photos of well EW-1 and the nearby UST fill port, both with and without vault lids, <br />and inside of the EW-1 well casing. <br />Central Valley Water board staff does not concur with Apex's theory of an accidental diesel <br />release into EW-1; however, staff concurs with groundwater remediation to reduce <br />petroleum concentrations in wells that exceed the State Water Resources Control Board's <br />Low Threat UST Case Closure Policy (LTCP). Following the 3' quarter 2021 sampling <br />event, please complete three batch extraction events consisting of 300 gallons removed from <br />each of wells EW-1 through EW-3 during 3' and 4th quarters 2021 and 1St quarter 2022. <br />Please monitor the batch extractions as proposed. <br />Please sample site monitoring wells and remedial wells EW-1 through EW-3 during Pt <br />quarter 2022, following the 3rd batch extraction event, and submit a GMR by 1 April 2022. <br />In this report, please include conclusions and recommendations related to current <br />groundwater conditions, free product, the efficacy of the batch extractions, and the need for <br />additional remedial action. Please include all free product measurement data collected during <br />the batch extractions in the historical groundwater data tables. <br />In the January 2019 directive letter, Central Valley Water Boards staff concurred with a <br />scope of work that included on-Site soil sampling and on- and off-site soil gas sampling. The <br />soil gas sampling was intended to assess the potential vapor intrusion risk to off-Site <br />properties. However, as conditions have changed in the past three years, after review of <br />current Site conditions Staff no longer believe that the soil gas sampling scope of work is <br />warranted. By 3 November 2021, please complete only the soil sampling scope of work as <br />discussed and concurred with in the January 2019 directive letter and submit a Site <br />Assessment Report. In this report, please provide discussion and comparison of the collected <br />data to criteria established in the LTCP. <br />This report, Second Semi-Annual 2021 Groundwater Monitoring, Batch Extraction, & Supplemental <br />Investigation Results Report (SAMR 3Q21), modified the typical SAMR scope to include activities <br />that address comment 1, the first of three batch extraction events in comment 2 (see Batch Extraction <br />section below), and comment 4 (Supplemental Site Investigation section below). The remaining <br />comments will be addressed in subsequent sampling events. Photos of EW-1 and the nearby UST <br />fill port are included in Appendix E.