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f <br /> Mr. Robert Trommer Page 6 of 7 <br /> Comments on CUF Site Closure Recommendations for Various Sites <br /> March 3, 2010 <br /> conducted. The EHD expects a very short remediation period that will not involve rebound <br /> testing as groundwater is currently too low to be significantly impacted. Assuming that the RP <br /> and consultant move forward on this site expeditiously, the EHD anticipates site closure in six to <br /> nine months. <br /> Claim No. 14558 -2353 Toste Road, Tract/ <br /> This site was being remediated by ozone injection at the time of the CUF site closure ' , <br /> recommendation in May 2009. The EHD directed cessation of the ozone injection and rebound <br /> testing by letter dated June 1, 2009. Since that time, groundwater analytical results have been <br /> favorable except for variable concentration of tert-butyl alcohol in monitoring well MW-7. The <br /> TBA has not been detected in any down-gradient wells, nor has MTBE. The EHD will present <br /> this site to the CVRWQCB as a closure candidate and initiate site closure procedures. The EHD <br /> anticipates site closure in six to nine months. <br /> Claim No. 15211 -23569 Santa Fe Road, Escalon <br /> During the last reported monitoring event (September 2008), the TPHg and benzene <br /> concentrations in monitoring well MW-3 appeared to have rebounded from 790 tag/L and 2.5 <br /> pg/L to 86,000 fag/L and 270 pg/L, respectively. Concentrations of the same analytes in MW-7 <br /> were also elevated at 2,100 lag/L and 230 pg/L, respectively. Impacted ground water around <br /> MW-3 was delineated by monitoring wells in three directions while it is similarly delineated in <br /> only one direction around MW-7. The impacted groundwater is in an area of high groundwater <br /> usage; in fact MW-7 is approximately 15 feet from a domestic well believed to be only 140 feet <br /> deep. <br /> In August 2008, a membrane interface probe (MIP) investigation in the core areas was <br /> conducted, but the results have not been submitted to the EHD for review. At this time the EHD <br /> believes additional monitoring of the core and inboard wells is needed to more fully understand <br /> the import of the last reported monitoring results. Additional monitoring of MW-3 and MW-7 <br /> would also be helpful. The EHD believes it would only be prudent to review the report of findings <br /> for the recent MIP investigation and conducting at least one more monitoring event before. <br /> initiating site closure. <br /> The major impediment for moving forward on this site is that the RP had received significant <br /> reimbursements from the CUF, but reportedly has not paid his consultant. The consultant is not <br /> conducting any additional work and is holding back the report of the MIP investigation. <br /> Claim No. 15890 - 545 E. Miner Avenue, Stockton <br /> A vapor intrusion and ESL evaluation of the site resulted in impacted soil gas and soil exceeding <br /> acceptable contaminant concentrations. By letters dated February 1, 2008, and July 11, 2008, <br /> the EHD commented on the results of a soil gas survey and soil impact investigation, noting that <br /> the TPHg concentrations in soil gas exceeded the San Francisco Bay Regional Water Quality <br /> Control Board's (SFBRWQCB) November 2007 environmental screening levels (ESLs) and <br /> directed additional vapor intrusion evaluation and either justification for leaving soil impacted <br /> above the ESLs in place or conducting site remediation. On November 19, 2009, an additional <br /> soil gas investigation was conducted and no other site work has occurred since the fourth <br /> quarter 2008. The EHD is awaiting a report of investigation for the November 2009 work and the <br /> technical justification for leaving soil impacted above ESLs for gross contamination and direct <br /> contact in place; assuming favorable results, the EHD anticipates closing the site in six to nine <br /> months. <br /> Comments on CUF Site Closure Recommendations 0310.doc <br />