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f <br /> 1301 Kettleman, Lodi <br /> Page 2 <br /> A soil gas survey is proposed in the work plan and the locations of the vapor probes are <br /> along product lines that were installed after the 1998 UST system removal. Justification <br /> for this investigation and its design was not provided. if it is suspected that the new <br /> UST system is leaking, the investigation should be performed as.an environmental <br /> assessment separate from the investigation of the contamination from the UST system <br /> that was removed in 1998. <br /> The work plan states that the lateral extent of the groundwater plume is not defined to <br /> the south or east. The groundwater plume is somewhat defined to the south with CPT-1 <br /> and MW-5 and is defined to the east with MW-6. T0he lateral extent of groundwater <br /> contamination is not defined to the west. Justification for the proposed locations of the <br /> shallow and deep monitoring wells was not provided. Groundwater samples from CPT2 <br /> justifies installation of a deep-screened monitoring well in that area but the well may <br /> need to be located south of CPT2 instead of north of CPT2 and MW3. Prior to EHD <br /> approval of the installation of the shallow and deeps wells south of Kettleman Lane <br /> justification for their installation must be submitted to EHD. <br /> Soil vapor extraction has been found to be an effective remedial alternative for soil <br /> contamination in Lodi commonly resulting in a beneficial effect on groundwater. There <br /> is documented soil and groundwater contamination in the areas of MW2 and MW3. The <br /> feasibility of soil vapor extraction for remediation in these areas should be evaluated. <br /> The contamination at this site has not been fully defined and may be spreading laterally <br /> and vertically which will increase the cost of investigation and remediation. If necessary, <br /> interim remedial action can be performed to prevent further migration of contamination <br /> and should be considered for this site. <br /> A revised work plan that includes justification for installation of the proposed wells to <br /> further define the contamination and evaluation of!feasible alternatives for cleanup of <br /> this site must be submitted by 28 February 2005. The justifications required may be a <br /> statement of need or purpose based on the site model and how the proposed action will <br /> address the concern, need or purpose. <br /> If you would like to discuss with EHD the site and requirements for investigation and <br /> remediation, please request a meeting with EHD. <br /> if you have any questions regarding this matter, contact Harlin Knoll at (209) 468-3442. <br /> Donna Heran, REHS, Director <br /> Env' onmental Health Department <br /> Harlin Knoll, Senior REHS Margaret agorio, REHS <br /> LOP/Site Mitigation Unit IV Supervisor <br /> cc: CVRWQCB—Jim Barton <br /> cc: AGE <br />