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Mr. Robert Garcia -2 - 8 July 2005 <br /> several years to complete, Leprino proposes evaluating available technologies at that time to take <br /> advantage of best current technology. <br /> 5. Monitoring and site closure. <br /> a. Leprino is conducting groundwater monitoring under Monitoring and Reporting Program(MRP) <br /> No. R5-2003-0808. Leprino proposes amending this MRP to focus on documenting remediation <br /> progress. <br /> b. Leprino proposes general remediation goals of removing as much SPH as reasonably practical <br /> and demonstrating that residual diesel concentrations in the groundwater have declined to acceptable <br /> levels. <br /> After achievement of these goals,Leprino will petition the Regional Board to deactivate the remediation <br /> systems and ultimately grant a no-further-action declaration for the site. <br /> Comments <br /> 1. Regional Board staff concur with enhancements to recover as much SPH as possible from the soil <br /> and groundwater,therefore we concur with the first three phases of work proposed by Leprino. <br /> However,the Cleanup Plan only provides the general locations for the proposed new extraction and <br /> monitoring wells. The final locations are to be chosen after the site assessment work is complete. The <br /> locations will be chosen based on permeability of the soils assessed by the boreholes and thickness of <br /> SPH on the water table. The proposed locations to the wells, and any supporting data such as boring <br /> logs, needs to be submitted to Regional Board staff for our concurrence prior to installation of the wells. <br /> 2. Leprino proposes evaluating current technologies for remediation of adsorbed TPHd from the soil <br /> and remaining dissolved-phase TPHd after recovery of all practical SPH has been achieved, as defined <br /> by remaining SPH in wells of 0.1 feet or less. Because Leprino proposes evaluating current <br /> technologies and proposing further remediation in the future, the Cleanup Plan as submitted is <br /> essentially an Interim Cleanup Plan. Regional Board staff concur with this approach. <br /> 3. The Cleanup Plan does not address the downgradient plume. Leprino needs to show that the plume <br /> is stable and that pollutant concentrations are decreasing. <br /> 4. Initially, all newly installed wells will be covered by the existing MRP. Regional Board staff <br /> concur with evaluating the MRP for its appropriateness after installation of the enhanced recovery <br /> features of the interim cleanup plan is complete. After all enhancements and adjustments to the product <br /> recovery system are complete, Leprino should submit their recommendations for revisions to the MRP. <br /> Downgradient wells also need to be sampled for parameters that will demonstrate that intrinsic <br /> bioremediation is taking place, such as dissolved oxygen,nitrates, sulfates and oxidation-reduction <br /> potential. <br /> 5. Regional Board staff concur with the general goals proposed in the Interim Cleanup Plan. Specific <br /> goals will be set in compliance with the Basin Plan and the Non-degradation Policy, that is, Leprino <br /> must show that they have achieved cleanup of the pollution to background levels if technically and <br /> economically feasible. If it is determined that it is not technically or economically feasible to achieve <br /> background water quality, Leprino must cleanup to applicable water quality goals. After Leprino <br />