SITE INFORMATION AND CORRESPONDENCE_1

Home Browse Search

ti f 110 Filbert, Stockton staff, USTCF staff, and Del Monte representatives. A workplan describing this scope of work was never submitted to PHS/EHD. On July 1, 1999, at the request of Del Monte, a meeting was held at PHS/EHD offices. In attendance at this meeting were Stephen Ronzone and Richard Fish representing Del Monte, Mark List of the Central Valley Regional Water Quality Control Board (CVRWQCB), Margaret Lagorio and Ronald Rowe from PHS/EHD. During this meeting Del Monte representatives acknowledged there were discussions between their consultant and USTCF staff on a work plan as outlined above, but did not agree that installation of air sparge or vapor extraction wells were part of the scope of work discussed. During the meeting(July 1, 1999) Del Monte representatives stated that fate and transport models had been generated for the site. PHS/EHD and the CVRWQCB expressed their concern regarding the reliability of any modeling effort for a site which is not characterized and is lacking the monitor well network to properly validate the modeling effort (no down gradient or water table intersecting wells, no lateral or vertical definition, and an incomplete understanding of regional groundwater flow dynamics). A copy of the modeling was not requested by PHS/EHD or provided by Del Monte. PHS/EHD had not approved nor directed the responsible party to perform this Fate and Transport Modeling. Therefore,this scope of work is not likely to be reimbursed by the USTCF. California Code of Regulations (CCR), Title 23, Division 3, Chapter 16, Article 11, Corrective Action Regulations, Section 2722 requires that the responsible parry shall submit workplans to PHS/EHD for all phases of corrective action. Furthermore. Section 2722 (d) states "The workplan shall include the proposed actions and a proposed schedule for their completion. The responsible party shall modify the workplan as necessary, at the direction of the regulatory agency". On July 1, 1999, Del Monte representatives presented to PHS/EHD a new scope of work(Version #5) to further characterize the site and requested comments from PHS/EHD. Consistent with previous workplans from Del Monte and CH2MHILL this June 30, 1999 revised summary scope of work fails to provide sufficient detail. Examples include no site plot plan showing the proposed locations for boreholes and monitor wells, no sampling frequency, no analytical methodology, no report content, no quality assurance plans, no schedule for completion, and the like. As a result PHS/EHD cannot provide approval for this scope of work at this time. For fundamental information on workplan and reporting content Del Monte and their consultant. CH2MHILL, should refer to Appendix-A Reports Tri-Regional Board Staff Recommendations For Preliminary Investigation and Evaluation of Underground Tank Sites 30 August, 1991 Central Valley Regional Water Quality Control Board (attached) for details prior to submitting any additional workplans to PHS/EHD. At the conclusion of the July 1, 1999, meeting, PHS/EHD staff asked Del Monte representatives for a verbal commitment to implement this scope of work regardless of USTCF cost preapproval. The point being that previous work plans, approved with conditions by PHS/EHD, which were not given preapproval by the USTCF, were not implemented. In addition, the scope of work that supposedly had been agreed to by PHS/EHD, USTCF, and Del Monte now is not going to be performed. Therefore, in order to move forward with the site investigation, Del Monte should be willing to implement work plans submitted to and approved by PHS/EHD. Del Monte representatives provided no assurance. 2