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� � a <br /> WEGE / Sanchez Property page 2 <br /> 1876 Country Club Blvd.,Stockton. <br /> Mr.Munch has indicated that the SWRCB-CUF has no objection with the destruction of the air sparge or <br /> horizontal vapor wells should direct removal of the contaminated soil prove to be more cost-effective. <br /> By not conducting a vapor test in the field and by not submitting a feasibility study,the conclusions reached <br /> for direct removal of the contaminated soil are biased. If vapor extraction conditions were promising for this <br /> site but the costs for additional well installation,extraction unit costs,time and maintenance, and reporting <br /> requirements were much more than direct removal,then PHS-EHD could concur with your conclusion. <br /> Unfortunately,no cost estimates were submitted to PHS-EI-ID for review. <br /> In order to evaluate the true cost-effectiveness of the remedial alternatives,PHS-EHD must be presented <br /> with two alternatives that mold work <br /> Regenesis Bioremeditation Products of San Juan Capistrano,California has estimates available for the costs <br /> associated with the installation of their product into the plume of this site. The costs for this alternative can <br /> be used in evaluating the most cost-effective remedial alternative. Only limited field tests are required for this <br /> alternative and PHS-EHD will evaluate "in-situ bioremediation" with ORC as an acceptable alternative. <br /> Please call Mr. Infurna to discuss some of the field tests that may be required. <br /> Your proposal for direct removal of the contaminated soil should address that over-excavation to 20+ feet <br /> below grade so close to the roadway may require shoring or some other method to ensure the road is not lost. <br /> In addition, groundwater at this site on May 14, 1999 was at 8 feet below the surface so de-watering costs <br /> should be incorporated into this alternative to ensure that digging to the depth proposed can be <br /> accomplished. <br /> Please consider utilizing the native clean soil located at the rear of the site as replacement soil for the direct <br /> removal alternative. If the clean soil is removed by scrapping it from the surface to approximately 3 feet <br /> deep,the depression left may be used as a bio-pad for the treatment of the contaminated soil to be removed. <br /> This would avoid hauling of the contaminated soil,costs for treatment at the landfill,and the costs for <br /> importing clean soil to be used as backfill. Your final cost-effectiveness study should include this option in <br /> the direct removal alternative. <br /> Please incorporate these comments into your cost-effective study due at PHS-EFID prior to enacting a <br /> remedial activity. You may contact Michael Infurna,Senior REHS,at(209) 468-3454 should you have any <br /> questions. <br /> Donna Heran,REHS,Director <br /> Environmental Health Division <br /> Michael J. Infurna Jr.,Senior REHS Margaret agorio,REHS <br /> LOP/ Site Mitigation Unit IV Supervisor <br /> MI/ <br /> c: CVRWQCB-Mark List,Sacramento. <br /> C! SWRCB CUF-Jim Munch,Sacramento. <br /> c: Manuel Sanchez— 1633 W.Walnut,Stockton,95203. <br />