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Former Columbo/Toscana Bakery - 2 - 23 December 2008 <br /> ' 1444 S. Lincoln St., Stockton <br /> ' estimated from $401,000 to $600,000 (cost varied due to uncertainty of disposal <br /> options, whether in-state or out of state). <br /> ' • ISCO (injecting modified Fenton's Reagent with Hydrogen Peroxide) was given a good <br /> short-term effectiveness rating and a very good long-term effectiveness, if three (3) <br /> separate injection mobilizations are conducted at depths of 25', 50', and 80' bgs; <br /> however, the $300,000 estimated cost was cited as the reason for not recommending <br /> ISCO. <br /> ' • BioS would target the USTs source area with four air injection wells screened at 55' and <br /> 80' bgs, injecting air at very low volumes (2 to 4 standard cubic feet per minute). BioS <br /> was given a minimal short-term effectiveness rating due to the anticipated slow <br /> ' biological response to the injection of air into the aquifer, and a very good long-term <br /> potential for success since the BioS system could be expanded offsite for a <br /> commingled plume, at an estimated cost of$145,000 over three years. <br /> ' While BioS was selected as the preferred technology, the Report did not include a <br /> recommendation for a BioS pilot study or a BioS workplan, nor provide a schedule for <br /> ' conducting BioS remediation. Instead, the Report recommended that "...remedial corrective <br /> actions..." be implemented upon establishment of the State Water Resources Control Board <br /> Underground Storage Tank Cleanup Fund Commingled Plume Account (SWRCB CPA) letter <br /> ' of commitment (LOC), to "...make the most efficient use of the corrective measures the <br /> technology and would reduce expenses..." The Report did not include an anticipated time <br /> schedule for receipt of the SWRCB CPA LOC. <br /> ' I also reviewed an email (Emaio from PSC dated 10 November 2008, a routine monthly <br /> update of the status of the SWRCB CPA LOC acquisition efforts by parties managing <br /> ' neighboring USTs sites. The Email also included a proposed schedule for implementation of <br /> an approved workplan and the report submittal for the soil vapor intrusion (SVI) investigation. <br /> The SVI workplan was approved by my Letter, which also requested a schedule for <br /> ' implementation of the SVI fieldwork, and submittal of the SVI report by 10 November 2008. <br /> The Email stated that there were concerns with false positives from the proposed soil gas <br /> testing (due to offsite sources mixing with onsite sources), and that questions on the fate and <br /> ' transport of the commingled plume would be answered by coordination of the proposed CPA <br /> sites monitoring in 2009. The Email suggested delaying the implementation and reporting of <br /> the SVI for one year, until the fourth quarter of 2009. <br /> ' Comments: <br /> ' 1. While Regional Board staff appreciate the extensive investigative work that Sara <br /> Lee has accomplished since taking over the site in 2007, the Report proposal to <br /> delay a remediation focused on your source area until after receipt of the SWRCB <br /> ' CPA LOC was addressed previously in my Letter, and also during our subsequent <br /> meeting on 18 September 2008. Both times staff stated that efforts to recruit <br /> applicants for the CPA should not adversely affect the cleanup progress of those <br /> sites involved in the CPA process. In fact, three nearby USTs sites that you have <br /> ' contacted for the CPA are conducting remediation efforts as: 1) full scale SVE/AS <br />