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z <br /> Yf <br /> r.� V <br /> . Former Unocal June 19, 2008 <br /> 1665 Pacific Avenue Page 2 <br /> Stockton, CA <br /> Contamination remaining in the soil was not addressed in the Response. As discussed in the <br /> EHD letter dated July 3, 2006, that was enclosed with a letter to you on March 26, 2008, high <br /> concentrations of contaminants were documented in the soil in the former dispenser area when <br /> vapor well VW2 was drilled. The "Conceptual Site Model" dated April 25, 2006 by ENSR <br /> discusses that the groundwater rising into the zone of contaminated soil creates a significant <br /> smear zone. The mass of contaminants remaining in the soil must be calculated and shown to <br /> not be.a continuing source of contamination to the groundwater and potential health hazards of <br /> direct exposure, vapor emission to indoor air and gross contamination must be addressed. <br /> The EHD and the CVRWQCB want sites to achieve closure within a reasonable time (10 years). <br /> Active remedial action must be performed at this site since according to the Response natural <br /> attenuation will take 22 years and this did not account for remaining soil contamination or the <br /> actual date the ozone system ceased operating. <br /> The EHD previously directed that monitoring well NP1 be destroyed and that a work plan for <br /> destruction of the well, an EHD well permit application and $89 permit fee be submitted to the <br /> EHD by June 16, 2008. To date none of these items have been submitted to the EHD. <br /> The EHD directs that the ozone system be placed back into operation by August 1, 2008 or a <br /> work plan be submitted for installation of some other type of wells for feasibility testing of other <br /> remedial options by that date and that the work plan, permit and permit fees for destruction of <br /> NP1 be submitted by August 1, 2008, as well. <br /> If you have any questions contact me at (209) 468-3449. <br /> Margaret Lagorio, REHHS <br /> Program Coordinator <br /> C' Jim Barton, CVRWQCB <br /> Ms. Helen McCrary, c/o Bank of Stockton, PO Box 1110, Stockton, CA, 95201 <br /> David Evans, ARCADIS, 10470 Old Placerville Rd Ste 110, Sacramento, CA, 95827 <br />