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got <br /> I have reviewed the recent letter dated 29 October 2008 from Vic Cherven, with <br /> Upgradient Environmental, to Mike Infurna, with the San Joaquin Co. Health <br /> Dept. (SJCEHD), regarding the Valley Motors unauthorized release case. The <br /> letter refers to a discussion I had with Clyde Hebbron, not Vic Cherven, and <br /> offers inaccurate statements as to said discussion. During a recent telephone <br /> conversation with Clyde, I was informed that he was working on a site that he felt <br /> was ready for closure but that SJCEHD wanted additional work on and requested <br /> an opinion (emphasis on opinion). I took the address and said I would do a brief <br /> review and call him at a later date. Following a brief review, which consisted of <br /> only review of the latest document found on Geotracker and the last couple of <br /> "activity" entries into Geotracker by SJCEHD staff (Mr. Infurna), I called Clyde <br /> back. I informed Clyde of the following: <br /> 1. The concentrations of contaminants were too elevated and, although have <br /> shown to be somewhat stable did not show a reasonable declining trend <br /> such that even if the oversight of the case were changed to the Regional <br /> Board closure could be considered, and additional remedial actions were <br /> necessary. <br /> 2. That SJCEHD staff has already received and approved actions (additional <br /> pilot testing) that both economically and time wise (provided that the work <br /> be conducted in a cost-effective manner) the best path for his client. <br /> Further, that the proposed, and approved, work would provide valuable <br /> additional data, and that the limited additional remediation that would <br /> occur that it may be enough to create a demonstrated declining trend . <br /> Further that the deadlines established by SJCEHD were timely. <br /> 3. That any location and sizing of the extraction wells needs to be adequate <br /> to ensure the optimal success as he (Clyde) was attempting to impact a <br /> small area, as an example - 4" instead of 2" wells, and the location of the <br /> wells should be in the heart of the plume, not on a fringe. <br /> 4. That I supported SJCEHD directive, and that he should begin as soon as <br /> possible so as to obtain the additional data that may prove assistive to him <br /> in a future case closure request to SJCEHD. <br /> 5. That I was working on a similar pilot test and based upon the data during <br /> the test was requested by the consultant (and was approved) to continue <br /> the test past the previous establish timeframe due to the remedial success <br /> occurring. Based on this, I suggested he be prepared to run the test <br /> longer as data dictated. <br /> 6. That our discussion was an opinion, based on limited data ONLY. And <br /> reiterated that he should proceed as directed by SJCEHD as it appeared <br /> to be the best course of action for his client overall. <br /> I am greatly disturbed to even see my opinion being used as is apparent, that I <br /> was not informed that the aforementioned letter was going to be prepared, that I <br /> did not speak at any time of this case with Vic Cherven (author of said letter), and <br /> more importantly that my statements were not accurately presented. I did not <br /> contact SJCEHD staff regarding my contact with Clyde as I fully supported the <br /> � KWA, vw�Vx lt�5�b% <br />