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45 East Harding <br /> Page 3 <br /> 5.2.1 Technology Screening/Remediation Design Considerations <br /> The plan stated that most of the hydrocarbon mass was located beneath the site in isolated soil <br /> columns located between 15 and 45 feet; yet, it was stated elsewhere that mass removal was <br /> localized near the top of the screen interval which is at 14 feet and that data suggested that the <br /> greatest petroleum hydrocarbon impact was located between the 25 to 30 foot interval. <br /> PHS/EHD disagrees with the isoconcentration contours which were illustrated on figures 4 - 9 <br /> and which may have been used to determine the area and mass of contamination. <br /> Remediation Design Conclusions <br /> PHS/EHD disagrees with the screening process utilized as presented in Table 2. <br /> 5.3.3 Alternative 2: SVE/Bioventing <br /> Once the effectiveness of the proposed SVE is demonstrated through soil sampling and residual <br /> soil contamination evaluation, PHS/EHD will evaluate the termination of the SVE system. The <br /> plan stated that a statistical method, American Petroleum Institute, Technological Limits of <br /> Groundwater Remediation: A Statistical Evaluation Method, would be used to determine <br /> asymptotic conditions. Please provide rationale why a groundwater method would be usedfor <br /> soil remediation evaluation. <br /> 5.4 Alternative Evaluation <br /> It is interesting to note that alternative 2: SVE/bioventing was selected because it would have a <br /> greater effect on groundwater remediation; yet no groundwater remediation was specifically <br /> proposed. <br /> Please submit a corrective action addendum addressing the issues discussed above by November <br /> 30, 1995. Please be aware that PHS/EHD has requested the submittal of a corrective action <br /> plan for a considerable length of time. Should an acceptable addendum not be submitted by the <br /> due date, enforcement action will be initiated. Any plans for development which may affect <br /> remedial action should be submitted to PHS/EHD as soon as possible. <br /> If you have any questions or to schedule a site inspection, please contact Mary Meays at (209) <br /> 468-0337. <br /> Donna Heran, REHS, Director <br /> Environmental Health Division <br /> Mary Meays, Senior REHS DianeM. inson, REHS <br /> Site Mitigation Unit Supervisor <br /> MM\45EHARD <br /> enclosure <br /> cc: Elizabeth Thayer, CVRWQCB (w/enclosure) <br /> CC: Carolyn Lawrence, William S. Moss Trust (w/enclosure) <br /> Cc: Robert Karsting, Manchester Club (w/enclosure) <br /> CC: Steven Krcik, Pacific Environmental (w/enclosure) <br />