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Mr.Michael Infurna <br /> October 30, 1996 <br /> Page 3 <br /> 1992 Vapor Extraction Testing <br /> Based on the results of groundwater monitoring activities, we have concluded that the <br /> installation of a vapor extraction remediation system is not necessary or warranted. Our <br /> rational is as follows: <br /> • the leak has been stopped and ongoing sources, including free product, have been <br /> removed or remediated; <br /> • the site has been adequately characterized; <br /> • the dissolved hydrocarbon plume is not migrating; <br /> • no water wells, deeper drinking water aquifers, surface water, or other sensitive <br /> receptors are likely to be impacted; <br /> • the site presents no significant threat to human health; and, <br /> • the site presents no significant risk to the environment. <br /> Taken in aggregate, I believe that the data supports a determination of"no further action" <br /> and a letter of case closure. <br /> MTBE detected in MW-6 <br /> We noted that MTBE was first detected at a concentration of 6.7 ug/1 during the October <br /> 1995 sampling event, and that concentrations of 2,700 ug/l and 4,100 ug/L were reported <br /> during the April 1996 sampling event. BP sold this site to the Tosco on August 1, 1994. <br /> We presume that any releases occurring after the sale would be the responsibility of the <br /> current owner/operator to address. If the concentrations of MTBE during the next <br /> quarter are lower that the results reported during the April 1996 sampling event, the <br /> occurrence of a subsequent release may be moot, provided that the chemical data further <br /> supports a finding for"no further action and case closure". <br /> San Joaquin County Deputy District Attorney <br /> It is unclear to me why"stricter guidelines" must be maintained now that a closure <br /> request is pending, and would like an explanation. I did not understand what was meant <br /> in your letter by"Current PHS-EHD policy requires that preparations for formal actions <br /> be copied to the DA so that an enforcement action file can be started in the event it is <br /> needed in the future." Please provide a copy of the policy you are referring to. <br />