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*-None F1SC '�- /f•j'd t:,r.+u r:n G BJ..�1 V a CA LIORNIA L,® \� lfrintr HF.`:r I'C)iIHIC"ii: Water Boards MAY 0 3 2012 Central Valley Regional Water Quality Control Boar$R NMENMLE4L7- MI7'jSERVICES H 1 May 2012 Estate of Barbara J. Hyduke Thomas O'Neill Cindy O'Neill, Executor .800 East Main Street 3465 Gleneagles Drive Stockton, CA 95202 Stockton, CA 95219 DOCUMENT REVIEW, VALLEYMOTORS, 800 EAST MAIN STREET, STOCKTON, SAN JOAQUIN COUNTY(RB CASE#390546) I reviewed Subject: Request for Feasibility Study and Work Plan (Letter) received 30 April 2012, submitted by Upgradient Environmental Consultants (UEC). The Letter makes assumptions regarding review of the entire file by Regional Board staff and requests clarification of directives given in my 23 April 2012 letter to you, with talking points numbered as First, Second, etc. First, the Letter is unsure as to whether I had read the 2008 Feasibility Study (FS) that San Joaquin County Environmental Health Department (SJCEHD) had approved for groundwater extraction (GWE), and due to SJCEHD unfamiliarity with in-well air stripping (IWAS), their concurrence to GWE over IWAS. The Letter asks if UEC might revisit IWAS, whether an amended FS is acceptable, or if a new FS is needed. I did review all documents submitted prior to SJCEHD referral of this case to the Regional Board. That said, my letter required an FS, and gave an example of an insitu chemical oxidation as a technology that would not draw a chlorinated solvent plume onsite and increase the cost of remediation to both Valley Motors and the State Water Resources Control Board Underground Storage Tank (UST) Cleanup Fund (Fund). Please note that resubmitting the 2008 FS and calling it an amended FS is not cost-effective or necessary, as the Fund has stated that they will not pay for the same document twice. The FS may include insitu chemical oxidation as a potential remedy as a resolve to the chlorinated solvent plume indicated above, and may also include IWAS. A cost comparison analysis is to be provided for all technologies in the FS. Second, the Letter requests clarification on the due dates in my letter, specifically whether the FS should be reviewed by me prior to submitting a work plan for a pilot study. This is a good point as UEC may be concerned that I may not be familiar with IWAS, as SJCEHD was not in 2008, and that I may not approve an IWAS pilot study work plan. Therefore the pilot study work plan due date will be amended in my review letter for the FS. However, please note that 60 days after my review letter for the FS is not acceptable for the submittal of a pilot study work plan. KARL E. LoNGLEY ScD. P.E., cr+Ain I PAMELA C. Ci REE00N P.E.. 4CEE, EXECUTIVE 01-TIGER 11020 5L,rr Center Drive#2.00,Rancho Corpova,CA 95670 I www walerboaroS c2 0ov!centratvalley CO nrc•ri.c L;rnrr;