Laserfiche WebLink
• u <br /> Mr. Brian Miller - 2 - 22 August 2002 <br /> soil samples in order to prepare a health risk assessment that identifies the primary constituents of <br /> concern, the relative risk posed to human health by these constituents, and the relevant exposure <br /> pathways, and then recommends cleanup goals that would not pose an unacceptable human health risk. <br /> The proposed remedial alternatives of paving and injecting HRC®will not address all the pollutants on <br /> site. WFS must evaluate other areas of potential soil pollution, such as the oil water separator. Board <br /> staff concurs with page B-3 of Appendix B that states, "It is highly recommended that any process under <br /> consideration should be proven by initial laboratory testing and then by subsequent pilot-scale trials." <br /> WFS needs to conduct bench-scale testing to determine if HRC®will remediate the constituents of <br /> concern in soil and will move through the soil and groundwater. <br /> The FS includes the cost of waste discharge requirements (WDRs) for the remedial alternatives that <br /> include discharge to the POTW. WDRs are not required for discharge to a POTW. However, WDRs are <br /> required to inject HRC® into the subsurface. WFS needs to recalculate the cost comparison based on <br /> this information. <br /> Board staff is not familiar with the use of HRC® for soil remediation. WFS must provide case studies or <br /> documentation of its use and effectiveness in soils with similar pollutants. By 20 September 2002, <br /> please provide the recalculated cost comparison along with case studies of HRC® for soil remediation <br /> and a discussion of whether WFS intends to proceed with the proposed HRC® injection pilot study. If <br /> so,by 22 November 2002, please submit a report detailing bench-scale laboratory testing results of <br /> HRC®with site soil and groundwater along with the rationale for only treating the soils in the area of the <br /> former ponds. If WFS intends to inject HRC®into the subsurface, it will need to submit Form 200 <br /> Report of Waste Discharge (RWD) along with a check for the amount of$200, the waste discharge <br /> requirement permit fee. Form 200 is attached and may be found on the Board's internet site at <br /> www.swreb.ca.gov/rwqcb5/available documents/index.html. It could take three to four months from <br /> submittal of a complete RWD until Board adoption of WDRs. <br /> Due to the constituent plume spreading into the adjacent residential area, resulting in the need for public <br /> participation, and the request for additional soil samples to complete a thorough health risk assessment, <br /> Board staff suggests WFS contact the Department of Toxic Substances Control to set up a voluntary <br /> cleanup agreement for that agency's input on the appropriate number and types of samples needed for a <br /> health risk assessment and for their expertise in public participation. If you have any questions, you may <br /> contact me at (916) 255-3119. <br /> am,Li2.GL- ;.�" <br /> DEVRA LEWIS <br /> Environmental Scientist <br /> Attachments (2) <br /> cc: Mr. Michael Infurna, San Joaquin County Environmental Health Department, Stockton <br /> Ms. Nancy Bishop, Agrium, Lafayette <br /> Mr. Eric Chase, Sierra-Pacific Group, El Dorado Hills <br />