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' mlo ical rechgics Inc. Page e 4 g g <br /> Sinclair Trucking <br /> SCM&CAP Addendum <br /> Project No. 1030.3 <br /> July 12,2004 <br /> ' shows remaining at the site. The subsequent Feasibility Study Addendum incorporates <br /> the practical and achievable removal of that contaminated soil. <br /> ' 2. In situ injection is no longer the remedial activity proposed for the site. However, the <br /> following may answer some concerns. <br /> a. Discussion with vendors and our ongoing experience at a Modesto site with similar <br /> lithology suggests that soil and groundwater remediation is achievable with ISCO <br /> technology. <br /> b. The word "easily" should not have been included. Not withstanding, given adequate <br /> injection point installation, the problem of low permeability of tight soils can be <br /> overcome. <br /> 3. In situ injection is no longer the remedial activity proposed for the site. However, the <br /> ' following may answer some concerns. <br /> Our goal is always to strive toward cleaning a site to background conditions when <br /> economically and technologically feasible. We feel ISCO has the potential of <br /> ' achieving the contamination goals set forth in the Basin Plan. Unfortunately, we <br /> have yet to find anyone in the industry that will claim they can achieve non-detect <br /> results. The 90-95% is the best "guarantee"the vendors will commit too. <br /> ' 4. In situ injection is no longer the remedial activity proposed for the site. However, the <br /> following may answer some concerns. <br /> a. The SJC/EHD May 2004 letter, comment #3, line 2 quotes GTI "The goal of in situ <br /> injection is a 90-95% destruction rate leaving 5-10% bound to soil and/or dissolved <br /> in groundwater". It appears the Feasibility Study Addendum suggests that the <br /> proposed in situ remediation will address both soil and groundwater contaminants. <br /> ' b. If two missing words are the issue we will change section 2.4 of the CAP and 2.2 of <br /> the Addendum: From: ...processes that treat the groundwater.... To: ...processes <br /> that treat soil and groundwater.... <br /> c. We assumed that SJC/EHD was aware that this technology is used in soil as well as <br /> ' groundwater remediation. In fact, with any remedial method, if the soil is not <br /> addressed, then the groundwater will not be remediated. Below are some additional <br /> sources which indicate that the technology is used in the remediation of <br /> ' contaminated soils and groundwater: <br /> 1. Interstate Technology Regulatory Cooperation's Technical/Regulatory <br /> Guidelines: Technical and Regulatory Guidance for In Situ Chemical <br /> ' Oxidation of Contaminated Soil and Groundwater, June 2001. <br /> 2. The EPA's Treatment Technologies for Site Cleanup: Annual Status Report <br /> (Tenth Edition), February 2001 indicates that 2% of the superfand sites use <br /> this method for soil remediation. It further states that the number is <br /> ' probably greater than 2%, but additional sites using the new technology <br /> have not yet reached completion and were not incorporated into the report. <br /> 3. The EPA's Field Applications of In Situ Remediation Technologies: <br /> ' Chemical Oxidation, September 1998 discusses the use of ISCO for soil <br /> remediation: _ <br /> 4. Pollution Technology Review No. 199: Catherine D. Chambers et al <br /> (1991): In Situ Treatment of Hazardous Waste-Contaminated Soils Second <br /> ' Edition. <br />