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s <br /> King Island Resort page 2 <br /> 11530 W . Eight Mile Rd , Stockton . fff <br /> Additionally, your consultant concluded that TPHd in ground water has declined <br /> significantly towards zero detection and added that limited petroleum hydrocarbon <br /> contaminants, including TPHg and MtBE , remain mobile and undefined . Although there <br /> was a discussion of additional site assessment in the SCM which included installation of <br /> additional monitoring wells and conducting an air sparge test, a work plan was not <br /> included in the SCM. <br /> The SCM also discussed potential exposure pathways that may be present at the site. <br /> Discussion of the pathways were limited to only direct contact with the soil or ground <br /> water at the site , such as digging or excavations from construction activities , that would <br /> present a threat to humans. Please evaluate the potential for vapor intrusion to current <br /> or future buildings and submit the report of finding to the EHD immediately. <br /> The construction specifications of the ART wells were not included in the CAP as <br /> requested by the EHD . If it is still your plan to incorporate the ART well technology, <br /> please submit exact well construction diagrams and narrative descriptions that clearly <br /> describe and show the dimensions of the ART wells . The screened interval of the <br /> casing , the diameter of the borehole, as well as all of the devices to be installed in the <br /> casing is to be included . Documentation (data from sites with similar characteristics that <br /> show the remediation was effective or regulatory agency letters) that ART has been <br /> successfully used in the Central Valley area should also be submitted . <br /> The concentration of MtBE in the ground water samples collected from MW-5, MW-6 , <br /> and MW-7 indicate that the plume is unstable and continues to be a threat to the <br /> drinking water well located just over 100 feet from the plume. In its April 7, 2006 <br /> correspondence, the EHD required interim remediation to be conducted at this site . As <br /> i of the date of this letter, an interim remedial action work plan has not been submitted to <br /> the EHD . <br /> i Ozone injection was discussed in the EHD's April 7 , 2006 letter and you were advised <br /> that prior to enacting an interim remedial action that includes ozone injection , a bench <br /> scale test is required . You were advised to submit the proposal for the bench scale test <br /> to the CVRWQCB for their review and Waste Discharge Requirement (WDR) <br /> evaluation . <br /> The CVRWQCB will comment on your bench scale test. Once the bench scale test has <br /> been completed and results have been submitted to the CVRWQCB , they will determine <br /> any WDR. <br /> The Plan was a report of findings for CPT- 1 through CPT-3 installations completed <br /> onsite during August 2004. At that time , laboratory data from the grab ground water <br /> below round surface (' bgs) <br /> CPT 1 at 82 feet <br /> sample collected in the <br /> MW 6 area from 9 <br /> I <br /> ndicated that MtBE was not detected . Additionally, the grab ground water sample <br /> collected from CPT-2 at 105' bgs supported the conclusion that MtBE was not present <br /> near the domestic drinking water well at this depth . MtBE was detected in the grab <br /> ground water samples from CPT-2 at 22' bgs and from CPT-3 at 57' bgs. <br /> i <br />