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1301 Kettleman, Lodi <br /> Page 2 <br /> demonstrated that soil vapor extraction (SVE) is a feasible method for removing <br /> adsorbed concentration in the soil vadose zone. EHD agrees with AGE's <br /> recommendation to implement interim SVE at your site. <br /> The dissolved MTBE, TPH-gas, and BTEX concentrations in ground water <br /> indicate an increasing, unstable plume that appears to be moving off-site and <br /> down-gradient to the south. EHD concurs with AGE's recommendation to begin <br /> a ground water pump-and-treat (PIT) program if the City of Lodi allows ground <br /> water discharge into their waste system (sanitary or industrial conveyances). <br /> The interim PIT will reduce mass and establish hydraulic control of the <br /> migrating/expanding ground water plume. <br /> In previous conversations and in written correspondence with you and your <br /> consultant (AGE), we agreed this project should move forward without further <br /> delays. The time and cost of cleanup will increase significantly as the plume <br /> travels beyond the on-site source of contamination. <br /> Please provide EHD and CVRWQCB with a Work Plan (WP) for SVE by August <br /> 1, 2006. If approval for waste discharge is granted by the City of Lodi, the WP <br /> should include PIT in conjunction with SVE and be submitted by August 1, 2006. <br /> Along with a WP, submit a permit application and necessary fees for additional <br /> remedial wells. Once the WP is approved and the permit is issued by END, the <br /> work must be completed within 45 days and cleanup implemented 90 day <br /> thereafter. <br /> If you have any further questions regarding this matter, contact Harlin Knoll at <br /> (209) 468-3442. <br /> Donna Heran, REHS, Director <br /> Environmental Health Department <br /> Harlin Knoll, Senior REHS Nuel Henderson, PG <br /> LOP/Site Mitigation Unit IV LOP/Site Mitigation Unit IV <br /> cc: CVRWQCB — Jim Barton <br /> cc: SWRCB, Cleanup Fund <br /> cc: AGE —Tim Cuellar <br />