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SMS Briners Field Work Page 2 of 3 <br /> ALREADY under the authority/oversight of an agency with regulatory ability would be a waste of your <br /> time. SJCEHD cannot comment on it. Now if you plan to'cc' SJCEHD with the work plan you will SEND to <br /> CVRWQCB/DTSC, than that's fine. But to send one for this site to SJCEHD for approval as the ONLY agency for <br /> review, nope, can't help you there.. <br /> But if you do ONLY geotech borings WITHOUT taking chemical analyses samples, then SJCEHD, Mr. Borges <br /> and his staff can help. The permit he issues for Geotech is limited to NO CHEMICAL samples/analyses. Only my <br /> UNIT IV, can issue chemical analyses sampling permits. And if NOT a UST site, then ALL of these contaminated <br /> sites must have approval by another reg agency. <br /> Clear? <br /> In case I understood your intent incorrectly, check out these questions and get back to me to clear up my <br /> confusion: <br /> 1-has your work been directed by an agency, ie: another RWQCB (Fresno office), DTSC, EPA or are you just <br /> doing it for fun? <br /> The RWQCB has required our proposed work for weighing the alternatives for closing the SMS <br /> Briners Evaporation Ponds via the site's WDRs (tentative order) dataed 7/15/04. <br /> 2- Have you been in touch with Mr. Hold? Does he know about these borings? Did he tell you to talk to me? <br /> Yes I have contacted him and told him of our plans. He said I should submit a work plan to both of you. <br /> 3-Whom are you working for? Kruger? SMS Briners?other? <br /> We are working for SMS Briners. <br /> 4-What do you hope to gain from this investigation? (ie: No Further Action letter, release of liability, due-diligence <br /> requirement, etc?) <br /> We will collect soils samples to perform lab testing for chloride concentrations. The soil chloride data will be used <br /> to develop a vadose zone model. Typical closure activities would include excavating all impacted soils (i.e. <br /> chloride-contaminated soils). However, preliminary testing at this site has shown that chloride concentrations in <br /> soils extend to below 100 feet bgs, so excavation of impacted soils may be infeasible. The vadose zone model <br /> will assist in evaluating alternative closure options. <br /> 5- Is this a property transfer investigation? <br /> No <br /> 6-what's your idea of"convention methods"of boring? <br /> Conventional methods would be hollow stem auguer(HSA). However, the rig will be equipped with balloon tires <br /> so we can be as mobile as possible on the soft, loose sediments of ponds. <br /> 7-Are you subcontracting to LSCE? <br /> No, not on this project. We are working directly for SMS Briners, but in cooperation with LSCE for developing <br /> pond closure alternatives. <br /> 8-Anything else I should know to help me decide if SJCEHD can help or refer you to the'right'agency. <br /> I think that covers it. Per Howard Hold, I am to submit our work plant to'both you and him. I think most of the <br /> other details will be summarized in the work plan. Please feel free to call (916-786-2424)or email me if you <br /> have any other questions, or feel, based on the information I've provided, that another department would be the <br /> right contact. Thanks! <br /> you may call me at(209) 468-3454 if you'd rather. <br /> -----Original Message----- <br /> From: Mathias, Maureen [mailto:mmathias@golder.com] <br /> Sent: Tuesday, October 12, 2004 1:20 PM <br /> To: Mike Infurna [EH] <br /> Subject: SMS Briners Field Work <br /> Hi Michael, <br /> I understand that you have been working with Till Angermann of Luhdorff and Scalmanini, Consulting <br /> 10/13/2004 <br />