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a , <br />Public Works - 2 - 12 July 2017 <br />1810 Hazelton Avenue <br />Stockton, San Joaquin County <br />The Addendum and 2 ' Addendum move some of the proposed locations presented in the <br />Work Plan, in order to avoid vertical migration of petroleum hydrocarbons into deeper water <br />in the CPT borings, and to better locate the proposed monitoring wells to properly monitor <br />transition (MW-9 and MW-10) and compliance (MW-8) zones in relation to ozone injection. <br />The 2'd Addendum supersedes the Addendum, and therefore, the Addendum is voided. <br />Central Valley Water Board staff concurs with the scope of work as proposed in the Work <br />Plan and 2nd Addendum, with the following comments: <br />In the Work Plan, Condor proposes to advance the CPT borings to 80 feet bgs. <br />However, in order to properly define the vertical extent of hydrocarbon impact to <br />groundwater, please advance these borings until hydrocarbon impacts are no longer <br />detected by in-situ tooling, or 80 feet, whichever is deeper. <br />In the Work Plan, Condor does not propose collecting groundwater samples from the <br />CPT borings. Condor proposes assessing impact to groundwater using only in-situ <br />membrane interface probe and hydraulic profile tool (MIP-HPT) technology. For the <br />purposes of confirmation, please collect at least two grab groundwater samples for <br />laboratory analysis from each CPT boring: (1) at the depth of highest hydrocarbon <br />impact to groundwater, and (2) at the maximum depth of hydrocarbon impact, as <br />based on in-situ analysis. Please analyze collected grab groundwater samples for <br />the same constituents analyzed during semi-annual groundwater sampling. <br />By 27 October 2017, please submit a Site Assessment Report. Please include <br />tables that present collected soil analytical data, as well as in-situ and laboratory <br />groundwater analytical data. Please also include an evaluation of shallow soil data <br />as compared to Direct Contact and Outdoor Air Exposure criteria presented in the <br />State Water Resources Control Board's Low Threat Underground Storage Tank Case <br />Closure Policy (LTCP). <br />Central Valley Water Board staff have the following additional comments on the current <br />status of the assessment and cleanup of the petroleum release from the Site: <br />In a letter dated 27 July 2016, Central Valley Water Board staff requested submittal of <br />a Notice of Intent (N01) Addendum. To date, the NOI Addendum has not been <br />received. By 29 September 2017, please submit the requested NOI Addendum, with <br />all additional information as requested in the 27 July 2016 letter. Ozone injection at <br />the Site cannot commence prior to submittal of the NOI Addendum and subsequent <br />issuance of a Notice of Applicability (NOA) by this agency.