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4 ' <br /> U <br /> Beacon#419 page 2 <br /> 2350 Waterloo Rd , Stockton <br /> Prior to advancing to the remedial phase for this site, Ultramar is required to delineate the <br /> contamination from the leak from the former underground storage tanks The result of this <br /> investigation is to be included in a report (Problem Assessment Report-PAR) and submitted <br /> to PHS-EI-D for evaluation The PAR is to include a discussion of the previous <br /> investigative efforts and conclusions based on field data that support site conditions and <br /> identify the limits of the contamuiation The size and mass of the plume is to be determined <br /> and the discussion is to include rationale why active remediation may not be needed or the <br /> types of active remediation that are or will be evaluated for this site <br /> Vrithout data from areas that are currently undefined,this site cannot complete the PAR. <br /> Depth specific site maps with lines of iso-concentrations of petroleum are to be included <br /> along with cross-sections and all are to be based on samples collected from the site <br /> Conclusions that are reached from areas that are not supported by field data (soil samples/ <br /> groundwater samples) will require further investigation before the site is to be considered <br /> "defined" and allowed to proceed to the remediation phase It is the opinion of PHS-EHD <br /> that this current proposal will not provide for the collection of data for some areas of <br /> concern <br /> Although the November 24, 1999 "Vapor Extraction/Air Sparge Test Report" concluded <br /> that SVE-AS was a viable alternative for remediating this site,there has been no discussion <br /> of the second alternative, as required by Corrective Action Regulations Corrective Acuon <br /> Regulations require contaminated sites within this Bann Plan area to evaluate at least two <br /> alternatives that could restore the groundwater's beneficial uses designation and submit <br /> those recommendations to PHS-EHD in a Feasibility Study for evaluation prior to <br /> advancing to the remedial action phase <br /> It is possible for sites to conduct remedial testing during the unestigative phase The <br /> Feasibility Study may be included within the PAR if completed, or subrrutted as a separate <br /> docurnent Either way, the FeasibilityStudyis to include field data for at least two <br /> alternatives that were evaluated and supports the recommended alternative PHS-EHD will <br /> review and comment on the Feasibility Study <br /> Please be advised that this latest addendum to the original 1997-work plan will not complete <br /> the investigative phase By not addressing the soil conditions deeper than 88' bgs at SB-6 <br /> area and by not placing a deeper screened monitoring well in this area, th proposal is <br /> inadequate In order to complete the investigative phase for this site,additional vertical <br /> unvestigauon of the SB-6 area and lateral definition of all vertical contamination is required <br /> In phone conversations with PHS-EM,Horizon Environmental Consultants have <br /> indicated that they consider the proposal complete and that they should be allowed to enact <br /> the plan as submitted Previous Ultramar correspondence stated that reviews by the State <br /> Water Resources Control Board"aye riot rjessar)' since no application for reimbursement has <br /> is been submitted By enacting this proposal without investigating the vertical extent at SB-6, <br /> it maybe interpreted that a cost-effective approach is not being utilized PHS-EHD may <br /> allow the enactment of the proposal as submitted with the understanding that additional <br /> investigation is required <br />