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Sent By: REGIONAL BOARD ANNEX; - 916 2553164; Feb-24-n5 10:49; Page 6/6 Chapin Bro rs Investment,Inc. - 4- 16 February 2005 1766 Monte iablo, Stockton, San Joaquin County el)Henderson, Margaret Liguria(Lagorio), Mr. Bill Little AGE Consultant, Mr. Brian iVmanJMr.James Barton RWCB Central Valley Region Not invited was Russell F. Ch ill (Phoperivowner)..." B this statement,the Petition implies that a meeting was held on 15 October 2003 that excluded the Pe itioner. However,this is a misrepresentation of the facts. It is my understanding the Petitioner was iny . ited by his consultant to attend a meeting at SJCEHD, but declined. Mr. Little,the Petitioner's c sultant did arrive at SJCEHD offices on 15 October 2003 after a regular County and State monthly mc eting,and did obtain information for the subsequent 19 December 2003 meeting,which included Chapin. • The Petition continues on page 5: ..At this meeting(15 October 2003)a directive was adopted to perform an operation hiatus the ound water extraction and treatment System, the extraction system operation suspend after 18 tober sampling..." The Pition cites part of an AGE letter dated 15 October 2003 title "Summary of Regulatory Meeting whichis not entirely accurate and makes statements taken out of context with the actual discussion. Mr. Li' le recommended a 30-day rebound test(hiatus)of the GWP&TS during the 15 October 2003 meetin . SJCEHD and Regional Board staff did not direct Mr.Little to do a rebound test we concurred to the rel. and test recommendation, which we understood to be made by the Petitioner's representative at the requesi of the Petitioner. • The Petition states on page 6: ' ...The fallowing items were discussed during the October 15 meeting. 1)... 4) The continued r. tnoval of ground water was not concurred by The Board. The Board indicated that soil vapor traction was the most E fective measure for the site, over and compared to the groundwater e rtraclion...6)... " Regioii d Board staff did not make an assessment of the effectiveness of the Petitioner's use of SVE or GWP ,as to which method was most effective for remediation for the site. As I remember the eonve ation,when asked by Mr. Little if SVE was more effective than pump and treatment for remed':ition,Mr. Newman responded that,in general, SVE is usually has a higher contaminate mass remov rate than groundwater extraction. Harlin Knoll, SJCEHD then spoke up that soil vapor extraction (SVE) ad 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 Wound ater levels rose into the silty,less permeable and SVE-amenable zone,which left groundwater pump a nd treatment as a more effective remedial alternative,as concurred by Regional Board staff on 5 April 2 00 during a meeting with SJCEHD,Mr.Chapin and his consultant,AGF.,. in sumi nary, 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 ye Irs,l would not eoneur to a site closure until such time the Petitioner can adequately domcrostrate when 'ater quality goals will be reached. Therefore,I recommend that the Petition for closure be denied. California Environmental Protection Agency a Recycled Paper