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2900 - Site Mitigation Program
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PR0508450
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SITE INFORMATION AND CORRESPONDENCE
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Last modified
5/29/2019 11:58:23 AM
Creation date
5/29/2019 11:10:41 AM
Metadata
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Template:
EHD - Public
ProgramCode
2900 - Site Mitigation Program
File Section
SITE INFORMATION AND CORRESPONDENCE
RECORD_ID
PR0508450
PE
2960
FACILITY_ID
FA0008087
FACILITY_NAME
DDJC-TRACY
STREET_NUMBER
25700
STREET_NAME
CHRISMAN
STREET_TYPE
RD
City
TRACY
Zip
95376
APN
25207002
CURRENT_STATUS
01
SITE_LOCATION
25700 CHRISMAN RD
P_LOCATION
99
P_DISTRICT
005
QC Status
Approved
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Mr. Phil Dawson <br /> August 26, 2009 <br /> Page 2 <br /> An August 25, 2009, conference call between all Parties identified that DLA required <br /> more time to review the State's proposal of a pump and treat remedial alternative <br /> necessitating that the informal dispute deadline be extended from August 28th to <br /> September 1, 2009. At that time, the Parties will then decide whether to initiate the <br /> formal dispute process if consensus is not reached on the preferred remedial <br /> alternative. <br /> Background <br /> On July 1, 2009 the State initiated informal dispute resolution for the DDJC-Tracy <br /> Northwest Corner Dieldrin Feasibility Study (FS), rejecting the FS due to discrepancies <br /> with the conceptual site model based on the aquifer pumping test results. On August <br /> 4th, 2009, tier 1, 2, and 3 representatives from DLA, DTSC, Water Board, and United <br /> States Environmental Protection Agency, Region IX, met to discuss the issues outlined <br /> in the State's correspondence. The meeting's outcome was that DLA would respond to <br /> the State's four shutoff criteria as part of a pump and treat system for the NWC dieldrin <br /> plume. On August 5, 2009, DLA's Project Manager sent the State an e-mail requesting <br /> that the State provide the design specifics (i.e. radius of influence, number of wells, well <br /> screen locations, etc.) for a conceptual pump and treat design. On August 6, 2009 the <br /> State responded to DLA stating that it would be willing to meet and discuss its <br /> interpretation of the conceptual site model to assist DLA and its contractor in developing <br /> a pump and treat system. During the conference call on August 10, 2009 between the <br /> State and DLA, DLA and its contractor were not willing to engage the State in its <br /> interpretations of site conceptual model, referring that the State did not have any new <br /> data to support its position, therefore, agreeing to disagree with the State's position. <br /> In the August 13, 2009 response letter DLA did not formally address the State's four <br /> pump and treat shutoff criteria stating that the criteria were "...contradictory, <br /> open-ended, and provided no clear end point or rationale." DLA's response letter also <br /> refuted several of the States technical assumptions without providing detailed <br /> justifications. <br /> The State is writing this letter to clarify the State's technical assumptions used in its <br /> evaluation of the observed data, followed by the perceived deficiencies in the remedial <br /> alternative analyses for selection of the preferred alternative. Below is a point by point <br /> response to DLAs assumptions presented in the August 13, 2009 letter. <br />
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