Laserfiche WebLink
GE <br /> GENESIS ENGINEERING&REDEVELOPMENT <br /> Howard F. Hold, P.G. <br /> May 29, 2009 <br /> Page 4 <br /> Section 5.3 of the Site Investigation Report proposed that an Engineering Feasibility Study be <br /> conducted to select an appropriate closure alternative for the Site based not just on cost, but on <br /> an evaluation of regulatory agency acceptance; reduction of toxicity,mobility, or volume; and <br /> technical feasibility. We believe that an Engineering Feasibility Study is required for the <br /> selection of the optimal closure alternative for the Site and that the"No Action" alternative <br /> should be evaluated because it considers the environmental consequences of not undertaking <br /> action and serves as a common point for comparing other alternatives and determining the <br /> magnitude of benefits and adverse effects. <br /> In addition, we feel that it is premature to direct the preparation of a final Closure Plan. Landfill <br /> Closure Plans are typically very detailed, and incorporate final grading and drainage plans,types <br /> and sources of cover materials, vegetative cover and landscape plans, and post-closure <br /> monitoring/maintenance requirements. Therefore, it is our view that a final remedy should be <br /> selected for the Site, and agreed upon by all parties before engineering design is initiated. As <br /> such, GE&R proposes submitting a Focused Engineering Feasibility Study and Conceptual <br /> Closure Strategy for RWQCB approval on or before September 15, 2009. That report will <br /> present a preferred closure alternative for the Site and a conceptual closure strategy. Once <br /> RWQCB staff have approved or commented on the preferred alternative, then a Closure Plan <br /> would be prepared for the Site. <br /> Should you have any questions or require additional information, please do not hesitate to <br /> contact me at(209) 599-2004. <br /> Respectfully submitted, <br /> Genesis Engineering & Redevelopment,LLC <br /> Christine W. Brown <br /> Senior Project Manager <br /> cc: Steve Rosenbaum,RWQCB <br /> Jerry Lile, DTSC <br /> Margaret Lagorio, San Joaquin County Environmental Health Department <br /> Mark Bradford,ERM West <br /> Ron Barber <br /> David Isola, Isola Law Group <br />