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during the test. Wells MW -1, MW -2, MW -3, and SVE-1 B were used as observation/monitoring <br />points. <br />The injection rate was initially set at approximately 2.5 cubic feet per minute (cfm) at a pressure <br />of 50 pounds per square inch (psi). Throughout the 96 -hour event, the flow rate varied between <br />1.6 to 2.5 cfm and the injection pressure ranged from 25 to 50 psi. Based on the performance of <br />the 96 -hour air sparge test, RDM estimates a conservative radius of influence of 30 feet. Results <br />of the air sparge pilot testing is summarized in RDM's Semiannual Groundwater Monitoring <br />Report — Third Quarter 2014 & Remediation Pilot Testing Results Report, dated November 9, <br />2014. <br />Between April 15 and April 29, 2015, RDM supervised the installation of off-site, downgradient <br />monitoring wells MW -5, MW -5B, and MW -6B, and the advancement of soil borings RDM-3 <br />through RDM-5 in the suspected former waste oil UST areas. In addition, RDM supervised the <br />destruction of the on-site abandoned well on April 14, 2015. Results of the investigation are <br />presented in RDM's, Report Summarizing Installation of Monitoring Wells MW -5, MW -58 and <br />MW -68; Additional Soil Assessment of Suspected Former Waste Oil UST Areas; and, Destruction <br />of On -Site Abandoned Well, dated July 1, 2015. <br />On October 6, 2015, RDM submitted its Site Conceptual Model, Low Threat Closure Policy <br />Evaluation, and Corrective Action Plan. The corrective action plan (CAP) proposed limited on-site <br />remediation (soil vapor extraction and air sparging) in the northeast corner of the property to <br />reduce secondary source concentrations. It was approved by the CVRWQCB on November 4, <br />2015. <br />The SWRCB, in its Review Summary Report — Additional Preliminary Review- November 2016 <br />(RSR), dated December 1, 2016, determined "the currently approved Corrective Action Plan did not <br />need to be implemented, and if implemented, the Responsible Party may not be reimbursed". <br />Instead, the SWRCB staff "recommended that the CVRWQCB direct the Responsible Party to <br />obtain a limited number of groundwater samples in the downgradient direction to verify plume <br />lengths to Water Quality Objectives." The SWRCB also stated in the RSR that "pending favorable <br />results of the off-site downgradient groundwater sampling (confirmation that plume lengths are less <br />than 1,000 feet), State Water Board staff recommend that Regional Water Board staff initiate <br />closure of the Site". <br />On February 16, 2017, the CVRWQCB issued a directive requiring two additional groundwater <br />monitoring events to evaluate trends of MTBE and 1,2 DCA in off-site, downgradient monitoring <br />well MW -5 and stated that if MW -5 concentrations continue to rise then additional plume delineation <br />downgradient of MW -5 may be required. To expedite the evaluation of groundwater trends, the <br />CVRWQCB requested sampling for two consecutive quarters in the first and second quarters 2017; <br />however, due to OSCF grant budget approval delays, the groundwater monitoring had to be delayed <br />until third and fourth quarters 2017. The directive also required continued semi-annual groundwater <br />sampling in the first and third quarters until a determination of no further action required is made by <br />the CVRWQCB. <br />