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Caltrans <br /> 1603 B Street <br /> Stockton CA <br /> Page 2 <br /> In fact, the Geocon recommendation describing the proposed CAP indicated that soil vapor extraction was <br /> the most feasible and cost effective interim corrective action option. The CAP stated that vapor extraction <br /> utilizing only one vapor extraction well,VW1, would be sufficient to remediate the approximately 5,000 <br /> cubic yards of contaminated soil, based on a minimum radius of influence (ROI) of 0.25 to 0.5 inches of <br /> water vacuum. Radius of influence does not necessarily infer an effective remedial zone of capture, since <br /> cleanup is directly dependent on the air flux through contaminated soil which in turn is a function of <br /> pressure gradient and soil permeability. <br /> As PHSIEHD indicated in correspondence dated August 29, 1995, the effectiveness of the vapor <br /> extraction well, VW1, is questionable due to its extremely long screened interval, from 12 to 98 feet bgs <br /> and the site's stratigraphy. The problems inherent with using a vapor extraction well with such a long <br /> screened interval are due primarily to the preferential vapor pathways through more permeable soil layers. <br /> Another problem with this particular well is the possible vertical leakage related to the sandy gravel used <br /> to backfill the former excavation. <br /> An aspect of the cost effectiveness evaluation of a proposed remedial alternative is to estimate the <br /> amount of time it will take to remediate the site. An industry standard which has been used is to calculate <br /> the amount of time it would take to remediate the 5,000 pore volumes of the soil requiring remediation at <br /> the site. The rational for the 12 to 18 month period of time required to remediate the site was not <br /> presented. <br /> Using a standard ROI based on achieved pressure measurements, clean-up times typically will be <br /> overestimated in high flow zones (high permeability) and underestimated in low flow zones (low <br /> permeability).Vapor extraction wells should be screened to maximize flow through the contaminated soil <br /> which the wells are installed to remediate. <br /> If the extraction rate of 5 pounds per day is used as the cost effective cut off for system operation, an <br /> inefficiently designed system may achieve an extraction rate reduction without the concomitant reduction <br /> of hydrocarbon concentrations throughout the area requiring remediation. Sol borings, for interim <br /> effectiveness evaluation would be required to demonstrate that the design is effectively remediating the <br /> contamination as proposed. <br /> Please prepare an addendum to address PHSIEHD's comments regarding the above referenced reports <br /> and to fulfill the requirements of the California Underground Storage Tank Regulations. <br /> If you have any questions, please do not hesitate to contact me at(209)468-0337. <br /> Donna Heran, REHS, Director <br /> �Environmental Health Division <br /> Mary Meays, Senior REHS Margaret Lagorio, REHS <br /> Site Mitigation Unit Supervisor <br /> MM/1603BSTREET <br /> cc: Elizabeth Thayer, CVRWQCB <br /> ee: Richard Walls, Geocon <br />