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Frontier Transportation Page 2 of 2 <br /> 425 Larch Road April 9, 2013 <br /> Tracy, California 95376 <br /> • The State Water Resources Control Board Cleanup Fund (CUF) has paid out <br /> $1,066,249.00 to this case as of November 2011, and the capital investment required for <br /> the infrastructure for HVDPE, which included installation of eleven HVDPE wells, has <br /> already been made — at the recommendation of AA&A, - which reduces the amount of <br /> money still available through the CUF to remediate and close the site; and <br /> • Considering that the estimated time to complete a second 30-day HVDPE remediation <br /> event will take ten weeks, compared to forty weeks for excavation, and ninety-two weeks <br /> for SME, HVDPE is potentially the 'quickest' method to implement and may result in the <br /> earliest site closure. <br /> In the opinion of the EHD, a compelling case, based on site-specific data, for abandoning the <br /> HVDPE remedial effort and investment, and starting from scratch on a new approach has not <br /> been made, and to the EHD, HVDPE appears to be the most economical method to implement <br /> to conserve funds for future case closure costs, i.e. proper destruction of the 39 wells installed <br /> as part of the corrective action for this case. As most of the 39 wells are in areas of known or <br /> suspected contamination, they must be destroyed by removal of the well contents in accordance <br /> with the San Joaquin County Well Standards. <br /> AA&A apparently interpreted the EHD permission in the EHD letter dated 17 December 2012 to <br /> end the HVDPE event early if the mass recovery rate dropped below one pound per day as a <br /> cleanup goal, which it is not, and AA&A thereby sees great uncertainty for achieving case <br /> closure through HVDPE. The EHD mentioned the one-pound-per-day recovery rate only for the <br /> purpose of ending the 30-day HVDPE event early if it became obviously ineffective before the <br /> 30 days had elapsed, thereby saving money for all involved. The mass recovery rate may have <br /> little to do with determining that the site no longer poses a threat to the environment, <br /> groundwater or to human health. The goal for the site remediation is to achieve sufficient <br /> contaminant mass reduction so that the site will qualify for case closure under the Low Threat <br /> Closure Policy criteria or the criteria of Appendix A of the Tri-Regional Board Staff <br /> Recommendations for Preliminary Investigation and Evaluation of Underground Tank Sites <br /> published by the Central Valley Regional Water Quality Control Board. <br /> By letter dated 17 December 2012, the EHD directed that the second phase of the previously <br /> approved 30-day HVDPE remediation events be implemented immediately. Please refer to this <br /> letter for related requirements when completing the second phase of this work. <br /> If you have any questions, please contact Vicki McCartney at (209) 468-9852, or by e-mail at <br /> vmccartney@sjcehd.com. <br /> Sincerely, <br /> Victoria L. McCartney, REHS� . Nuel C. Henderson, Jr., PG <br /> Senior Registered Environmental Hea Specialist Engineering Geologist <br /> c: Ms. Gabriele Baader, PG, Ami Adini & Associates, Inc., 4130 Cahuenga Blvd., Suite 113, <br /> Los Angeles, California 91602 <br /> Mr. James L.L. Barton, PG, California Regional Water Quality Control Board Central Valley <br /> Region, 11020 Sun Center Drive, Suite 200, Rancho Cordova, California 95670 <br />