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' to teal reckntcs lnc G� g Page 6 Sinclair Trucking SCM&CAP Addendum Project No. 1030.3 July 12,2004 2.4 Justification of Soil Excavation ' Several factors justify the performance of soil excavation at the Sinclair Trucking site. Additional Costs ' • The extended groundwater monitoring that would be required will potentially add tens of thousands of dollars to ISCO remediation. These additional costs would include purging wells, water disposal, sample collection, laboratory analyses and reporting. ' • Bench-scale testing now required by the RWQCB would add up to $10,000 per water or soil sample, per zone of contamination. If multiple soil types occupy a zone and there are several zones of contamination it is reasonable to conclude the bench-scale testing ' can reach nearly $100,000.00. o In addition, GTI has been trying to find laboratories from coast to coast that can meet the testing guidelines provided by the RWQCB. Only one laboratory has responded to date stating it can meet the requirements as specified in the RWQCB letter. o In addition, there is no understanding with the Fund as to reimbursements for the bench-scale tests. If denied our clients could be left holding the proverbial bag. ' • Waste Discharge permitting requirements for San Joaquin County regarding the injection of peroxide would significantly increase costs of ISCO remediation. These costs were unexpected and not included in the original estimate because all other locations we are involved with in California which have ongoing peroxide injections are not required to have these permitting requirements. --7 • If indoor air monitoring were required for ISCO processes the costs would increase by ' approximately $3000 per test. • Although our goal is always to strive toward cleaning a site to background conditions I when economically and technologically feasible, local vendors cannot guarantee more )V1 'Zdd than 90-95% removal rates. This is unacceptable to the county and reaching these goals may require additional remedial activities (and associated costs) and extend the length feu �` • of the remediation. ' U In the worst case scenario: The willingness of Mr. and Mrs. Sinclair to shoulder some of Mrd t Ju�14 - the costs associated with soil excavation that may not be covered by the fund could reduce the estimated costs of excavation. ' • The cost estimate for soil excavation is the worst-case scenario estimate (See Section 2.2 above). If conditions during excavation are favorable the final costs will be lower than estimated. ' Time Considerations rA�X 0,1 • Mr. and Mrs. Sinclair are under time constraints in regards to the property and prompt remediation is of the essence. L• Regarding Bench-Scale Testing: - Questions to the RWQCB -have been met with the = Y' oS response of"be patient we are working on it". Without having policies and procedures in place this process may add significant time to the project. Some of the questions posed have been: Does every soil type in the zone need to be tested? If multiple zones of ,5�� contamination are identified does each zone need to be tested? Is the zone of injection