SITE INFORMATION AND CORRESPONDENCE_FILE 2

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Chapin Brothers Investment, Inc. -4 - 16 February 2005 1766 Monte Diablo, Stockton, San Joaquin County (Nuel)Henderson, Margaret Liguria(Lagorio), Mr. Bill Little AGE Consultant, Mr. Brian Newman/Mr. James Barton RWCB Central Valley Region Not invited was Russell F. Chapin (property owner)..." By this statement,the Petition implies that a meeting was held on 15 October 2003 that excluded the Petitioner. However,this is a misrepresentation of the facts. It is my understanding the Petitioner was invited by his consultant to attend a meeting at SJCEHD,but declined. Mr. Little,the Petitioner's consultant did arrive at SJCEHD offices on 15 October 2003 after a regular County and State monthly meeting, and did obtain information for the subsequent 19 December 2003 meeting, which included Mr. Chapin. • The Petition continues on page 5: "...At this meeting(15 October 2003)a directive was adopted to perform an operation hiatus the ground water extraction and treatment system, the extraction system operation suspend after 18 October sampling... " The Petition cites part of an AGE letter dated 15 October 2003 title "Summary of Regulatory Meeting", which is not entirely accurate and makes statements taken out of context with the actual discussion. Mr. Little recommended a 30-day rebound test(hiatus) of the GWP&TS during the 15 October 2003 meeting. SJCEHD and Regional Board staff did not direct Mr. Little to do a rebound test we concurred to the rebound test recommendation,which we understood to be made by the Petitioner's representative at the request of the Petitioner. • The Petition states on page 6: "...The following items were discussed during the October 15 meeting: 1)... 4) The continued removal of ground water was not concurred by The Board. The Board indicated that soil vapor extraction was the most effective measure for the site, over and compared to the groundwater extraction...6)... " Regional Board staff did not make an assessment of the effectiveness of the Petitioner's use of SVE or GWP&T, as to which method was most effective for remediation for the site. As I remember the conversation,when asked by Mr.Little if SVE was more effective than pump and treatment for remediation,Mr.Newman responded that, in general, SVE is usually has a higher contaminate mass removal rate than groundwater extraction. Harlin Knoll, SJCEHD then spoke up that soil vapor extraction (SVE)had been more effective in the beginning(1990's)when the water table was depressed below current levels and more of the permeable sands were exposed to vapor extraction. Subsequently site groundwater levels rose into the silty, less permeable and SVE-amenable zone,which left groundwater pump and treatment as a more effective remedial alternative, as concurred by Regional Board staff on 5 April 2000 during a meeting with SJCEHD, Mr. Chapin and his consultant, AGE. In summary,post remediation monitoring is standard practice for all Regional Board lead sites prior to closure concurrence. If the Petition site were a Regional Board lead site and the Petitioner presented the closure request for no further action in this manner, showing no decline in modeled concentrations after nine years,I would not concur to a site closure until such time the Petitioner can adequately demonstrate when water quality goals will be reached. Therefore,I recommend that the Petition for closure be denied. California Environmental Protection Agency �� Recycled Paper