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Mr. Richard Brandes - 2 - 15 July 2003 <br /> 3. Section 3.4 of the Work Plan discusses the construction of the remediation system but <br /> does not include how the system will be protected from weather, traffic, or other potential <br /> hazards. ST Services must include this information. <br /> 4. Section 5.2 of the Work Plan discusses the chemical analyses for the groundwater <br /> samples. The Work Plan does not propose analyzing for total petroleum hydrocarbons as <br /> gasoline and diesel during the monthly sampling, but does not provide the rationale for <br /> not including these analyses. One of the purposes for monitoring is to determine the mass <br /> removed. ST Services needs to discuss how this purpose will be met if gasoline and <br /> diesel are not analyzed. <br /> 5. Page 15 of the Work Plan discusses the addition of nutrients on a monthly basis. For the <br /> purposes of the WDRs, Regional Board staff needs an estimate of how much nutrients <br /> will be added monthly so that provisions may be set in the WDRs. <br /> 6. In order to set provisions in the WDRs, we need to know the background concentrations <br /> of constituents that are naturally-occurring (i.e., nitrogen, phosphorus, potassium, etc.) <br /> that may be influenced by the addition of the bacterial consortium, enzyme <br /> enhancements, and specialized nutrients. <br /> 7. The Work Plan does not include the proposed injection rate of the treated groundwater. <br /> ST Services must provide this information. <br /> 8. The Work Plan does not include a contingency plan for the event that background <br /> concentrations exceed provisions set in the WDRs. ST Services must include a <br /> contingency plan. <br /> 9. The health and safety plan included in the Work Plan does not include written or visual <br /> directions to the nearest hospital. ST Services must include this information. <br /> 10. Figure 3 of the Work Plan should include an arrow to show the groundwater flow <br /> direction to justify the proposed monitoring well locations. <br /> The Report of Waste Discharge is not complete until this additional information is provided. In <br /> order to keep the timeline proposed in the Work Plan, this additional information is need by <br /> 30 July 2003. If you have any questions, you may contact me at (916) 255-3119 or by email at <br /> le�wisd@rb5s.swrcb.ca.gov. <br /> DEVRA LEWIS <br /> Environmental Scientist <br /> cc: Ms. Margaret Lagorio, San Joaquin County Environmental Health Department, Stockton <br /> Port of Stockton, Office of Environmental and Regulatory Affairs, Stockton <br /> Ms. Amanda Spencer, Hart Crowser, Inc., Lake Oswego, Oregon <br />