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500 East Grant Line <br /> Page,3 <br /> Alton indicated that remedial options and final remedial pian were presented in <br /> the Problem Assessment Report (PAR) dated September 30, 1991: PHS/EHD <br /> indicated in correspondence-dated November 8, 1991 that PHS/EHD did not <br /> agree with the conclusion presented in the PAR that "No further investigation or <br /> remediation of adsorbed-phase hydrocarbon constitutes in the soil appears <br /> warranted at this time." PHS/EHD requested further investigation of the on-site <br /> and off-site soil contamination. PHS/EHD also requested that soil and <br /> ;,groundwater remedial options/additional investigation should be. included in a <br /> draft Final Remediation Plan to be submitted by December 20,;1991. PHS/EHD <br /> received Alton correspondence that the additional,investigation°requested and <br /> interim remediation would proceed prior:to submittal of a Final Remediation <br /> Plan. <br /> 'PHS/EHD indicated in correspondence dated April 8, 1993, that since <br /> ,groundwater remains contaminated, the information gathered in aquifer testing <br /> should be-used to develop a Final Remediation Plan to remediate both soil and <br /> groundwater contamination_`which has been documented. Furthermore, PHS/EHD <br /> requested that a draft FRPbe submitted by June 30,.1993, with the proposed risk <br /> 'assessment report. <br /> Alton disagreed with Geo'Matrix's comment that a "significant layer of gasoline and <br /> diesel is stall present under.much of the site below`a.depth of 10 feet". Given the <br /> results of the most recent soil investigation, the installation of monitoring wells <br /> AW10, AW11, and AW12,- it would appear that tl ere was a significant layer of <br /> "gasoline and diesel stili present under the.site though the-horizontal extent is <br /> unknown. (See comments on the Supplemental Site Investigation) <br /> Alton disagreed with the interpretation by Geomatrix of what constitutes free <br /> ;product. While the disagreement is technical, based on experimental solubility <br /> values, the concentrations detected in soil are clearly significant and groundwater <br /> has been impacted. Furthermore, the concentrations remaining in the soil <br /> continue to pose a threat to groundwater. <br /> Finally, Alton disagreed with the Geomatrix statement that the review of remedial } <br /> technologies was "completely inadequate for evaluating the feasibility and costs <br /> associated with the technologies." Alton stated that `'the implicit intent of any <br /> remediation technology is-to reduce potential risks to human health in the <br /> environment." While this intent is correct, the Water Quality Goals dated May <br /> 1993 prepared by the Central Valley Regional Water Quality Control Board, <br /> states that "Ground waters 'shall.not contain chemical iconstituents in <br /> concentrations that adversely affect beneficial-uses." 'Furthermore, "Ground <br /> waters shall not contain taste- or odor producing substances in concentrations that <br /> cause nuisance or adversely .affect beneficial uses." .',. <br /> 1 <br /> ,. l <br />