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VOW <br /> MICHAEL D & SHARON OLIVAREZ <br /> 300 SOUTH CALIFORNIA <br /> Page 2 <br /> additional monitoring wells at this site at this time. PHS/EHD considers this proposal to be <br /> premature. Groundwater gradient and contaminant distribution can be ascertained accurately by <br /> placing one additional monitoring well in a down gradient position,North-easterly, assuming CGI <br /> initial gradient determination is correct. This monitoring well may be placed off site, possibly <br /> on the north side of Lafayette Street directly across from the parcel requiring a revokable permit <br /> from the City of Stockton or CalTrans. Application to the appropriate agencies in a timely <br /> manner will diminish time in processing. In addition,PHS/EHD staff does not concur with CGI <br /> recommendations to perform pump tests at this time, in the event CGI has additional relevant <br /> information to support their proposal please submit this information for review. <br /> In telephone conversations (September 19, 1995) with CGI and State of California Water <br /> Resources Control Board Underground Storage Tank Cleanup Fund (USTCF) staff, PHS/EHD <br /> representatives discussed the employment of push point assessment tools for this site recognizing <br /> the soil lithology as amenable to such techniques. In short, PHS/EHD recommends that CGI use <br /> push point technologies to assess the site with not less than one continuous core in order to <br /> determine appropriate locations for future monitoring, vapor extraction, air sparge and or air inlet <br /> well locations when justified. Push point technology can be economically effective and efficient <br /> rapidly generating soil samples, soil gas surveys, and groundwater grab samples while reducing <br /> the quantity of boring spoils to be disposed. PHS/EHD recommends mobilization of work crews <br /> be minimized to reduce costs. As monitoring well and SVE locations are approved, attempt to <br /> organize the installations in one mobilization when possible. PHS/EHD takes this opportunity <br /> to remind responsible parties to submit all site work cost estimates included in PHS/EHD <br /> approved workplans to USTCF offices for pre-approval prior to initiating work at this site as a <br /> means to virtually insure reimbursement. <br /> PHS/EHD does not concur with CGI proposals to install vapor extraction wells at this site <br /> without further assessment. PHS/EHD recommends that CGI amend its workplan to include <br /> proposals for acquisition of geologic and general site data which supports the feasibility of soil <br /> vapor extraction(SVE) for this site. This data should include but shall not be limited to, intrinsic <br /> permeability of the soil, soil volumes to be treated with mass volume calculations, pore volume <br /> calculations, soil structure and stratification (cross-sectional diagrams) from sampling intervals <br /> of sufficient frequency, depth to groundwater, moisture content, constituent volatility, estimates <br /> of pneumatic conductivity, and rationale for SVE pilot system design. This rationale shall <br /> include a design radius of influence with proposals including lateral and vertical spacing of <br /> extraction and inlet wells, well head vacuum, pump type and sizing, efficient piping sizing and <br /> configurations including appropriate permanently placed instrumentation for system effectiveness <br /> evaluation. In proposing this system please take into consideration discharge, monitoring <br /> requirements and site construction limitations. <br />