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Mr. Donald Rodgers - 2 - 27 December 2007 <br /> 515 West Charter Way, Ston, San Joaquin County • <br /> Comments: <br /> 1. The FS needs to include current cost estimates for each alternative, in order to provide a more <br /> focused cost comparison and to fully evaluate cost effectiveness. Please provide the four cost <br /> estimates in a letter response by 18 January 2008. You may email this information to me. <br /> 2. The Workplan should include one additional deep zone (75 to 85 feet bgs) monitoring well <br /> (one deep well is currently installed as MW-4D and one is proposed as MW-11 D), to provide <br /> the minimum three points necessary to determine groundwater flow direction and gradient in <br /> that zone. I suggest that the third deep well be located nearer MW-101, to allow adequate <br /> separation. Provide a revised Figure 9 showing the proposed location of the additional deep <br /> well by 18 January 2008. You may email this figure to me. <br /> 3. A report of the investigation, due by 30 April 2008, should also include a recommendation for <br /> any additional investigation (if necessary), and a schedule for corrective action. <br /> 4. 1 concur conditionally with Shaw's selection of BIO to remediate groundwater (pending receipt <br /> of the above cost estimates). A pilot study for oxygen injection is necessary to determine <br /> whether this alternative is effective. Once I have reviewed the cost estimates and notified you <br /> that BIO has received final concurrence, submit a pilot study workplan by 21 March 2008. <br /> 5. The Workplan includes Figures 3 and 4, which present isoconcentration contour maps of <br /> benzene in the shallow and deep zones from results of quarterly monitoring in September 2007. <br /> As of this date, the Regional Board has not received paper copies of the quarterly report, nor <br /> have the quarterly report or these two reviewed documents been submitted to GeoTracker. <br /> Submittal of all documents to this agency is a requirement for your case, as stated my <br /> 6 June 2007 letter. We require a paper copy, while the San Joaquin County Environmental <br /> Health Department (SJCEHD) and State Water Resources Control Board (SWRCB) require <br /> electronic submittals to GeoTracker. Submit the documents in paper to me and electronically to <br /> GeoTracker by 18 January 2008. <br /> 6. There are two boxes of SWRCB Underground Storage Tanks (UST) Cleanup Fund (CUF) <br /> invoices in my possession, which you mailed to us without an explanation or instructions. <br /> Please contact me as soon as possible to discuss them, as we only keep copies of public <br /> records (letters and documents) in the public file. If you need assistance from the SWRCB <br /> UST CUF with your invoices, we can provide contacts for a meeting with them. If they require <br /> our assistance, we can attend that meeting. <br /> Please procure all necessary permits and clearances, and provide the SJCEHD and myself at least <br /> three working days notice prior to commencement of field activities. If you have any questions you <br /> may call me at (916) 464-4615, or email me at jbarton@waterboards.ca.gov. <br /> James L. L. Barton, P.G. <br /> Engineering Geologist <br /> Enclosures <br /> cc: Mr. Mark Owens, UST Cleanup Fund, SWRCB, Sacramento <br /> Ms. Margaret Lagorio, San Joaquin County Environmental Health Department, Stockton <br /> Mr. Dan Wynne, Shaw Environmental, 1326 North Market Blvd., Sacramento 95834 <br />