SITE INFORMATION AND CORRESPONDENCE_FILE 2

Home Browse Search

Ron Duff, PE Page 2 of 3 Re: Russell Chapin Petition 17 February 200919 March 2009 1766 Monte Diablo Avenue,Stockton,California that Mr. Chapin was aware of his consultant dropping by and declined to be there himself. The reason the Regional Board people were present at the EHD office was to attend the monthly LOP staff meeting, which the Regional Board representative routinely attends. The EHD document dated January 25, 2005, briefly discusses this meeting. Since that incident the EHD will not meet with consultants in our office to discuss any site issues unless the EHD has verified that the responsible party (RP) is aware of the meeting. Mr. Chapin states several times in the February 2009 Petition that 95% of the contaminants have been removed from his site and that only a residual 5% remains. The EHD does not believe that this is correct; in 2004 ATC Associates estimated that 5,733 pounds of contaminants remained in the subsurface, an estimate the EHD considered to be too low as data just previously acquired from soil samples collected under the building on the site had not been utilized in the estimate; however, assuming the estimate is approximately correct and that AGE's estimate that 957 pounds of contaminants were removed by GWE through fourth quarter 2008 is correct and that approximately 2,645 pounds (407 gallons) had been removed by SVE, a total of 3,602 pounds of contaminants have been removed though engineering technology. Assuming that the ATC estimated 5,733 pounds were the original contaminant mass, not the 2004 mass, at best approximately 62% of the original mass has been removed, not 95 %. While this may be a significant mass reduction, it should be noted that the dissolved contaminant concentrations typically rebound sharply during periods lacking active remediation. Mr. Chapin often includes the statement in his appeals and petitions he putatively attributes to the EHD that "Cost is a non-issue"; where this came from I do not know. I have neither uttered it nor do I recall ever hearing any EHD staff say it in any meeting; the EHD strives to be sure that approved actions are cost effective, although this is always a challenge as consultants rarely provide the full basis in cost or effectiveness to support their evaluation of cost effectiveness. The EHD has stated that compliance with directives is not contingent on Cleanup Fund reimbursement; that said, the EHD does attempt to limit directives to those activities that are reimbursable and still properly investigate and manage our LOP sites. Finally, I wish to reiterate that I regard our LOP staff as being quite competent and knowledgeable workmen in the limited slice of the `geological' field in which we work. Their knowledge and understanding of their sites is impressive to me and is the primary resource that enables me to do my job. They review the reports and proposals for their sites, and provide questions and comments that I usually find go right to the core of the issues on the site. To my knowledge, I am the only one in this office that issues geological interpretations or practices geology. In my opinion, competent and knowledgeable consultants should be able to answer any question or objection posed by our staff; but sadly, the response to questions or disagreement from our staff is often met by statements such as Mr. Chapin's deriding the staff as unqualified to ask questions, and certainly unqualified to object to their recommendations or proposals. Ron Duff Letter 0309