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Ms. Angela Lee <br /> Humbrook Holdings,LLC <br /> February 12,2014 <br /> Page 4 <br /> Since groundwater monitoring was initiated at the site in September 2011, measured depth to <br /> groundwater in the monitoring wells has ranged from approximately 47 to 50 fbgs. <br /> Additional Soil and Groundwater Assessment <br /> Based on review of the results from previous environmental investigations performed at the site by <br /> other consultants, the following scope of work for additional soil and groundwater assessment was <br /> proposed in RDM's Workplan that was approved by the CVRWQCB in its letter dated February 13, <br /> 2013 (Enclosure B): <br /> • Installation of five offsite groundwater monitoring wells (MW-4 through MW-8) to further <br /> assess the lateral extent of the volatile organic compounds(VOC) groundwater plume; <br /> • Advance one soil boring immediately adjacent to the suspected former dispenser island; <br /> • Advance one cone penetrometer test(CPT)boring onsite to a depth of approximately 100 feet <br /> • below ground surface (fbgs) and grab one groundwater sample to further assess the vertical <br /> extent of the VOC groundwater plume; <br /> • Installation of two nested soil vapor extraction (SVE) wells (SVE-IA/B and SVE-2A/B), <br /> each screened from 10 to 25 fogs and 35 to 50 fogs, and one air sparge (AS) well (AS-1) <br /> screened from 63 to 65 fogs; <br /> • Conduct a 24-hour(12 hours on each nested SVE well) SVE pilot test and a 96-hour AS pilot <br /> test. <br /> Even though RDM's Workplan had already been approved by the CVRWQCB, our proposed scope <br /> of work had to be revised following budget review by the State Water Resources Control Board <br /> (SWRCB), Technical Review Unit of the Underground Storage Tank Cleanup Fund (USTCF). The <br /> USTCF issued a cost pre-approval letter, dated April 30, 2013, which denied RDM's requested <br /> budgets associated with remedial pilot testing (installation of the remedial testing wells SVE-1A/B, <br /> SVE-2A/B, and AS-1; remedial pilot testing activities; remedial testing results report; and preparation <br /> of a Corrective Action Plan (CAP)/remediation system design). In its letter dated May 22, 2013 <br /> (Enclosure B), the CVRWQCB addressed its concems/issues with the USTCF's April 30, 2013 cost <br /> pre-approval letter and directed RDM to perform a phased approach to the approved Workplan. In the <br /> phased approach, the CVRWQCB directed RDM to install a soil boring rather than a nested soil <br /> vapor extraction well at proposed location SVE-1A/B,beginning soil sampling at 5 fbgs and at 5-foot <br /> intervals until there was no evidence of contamination or until groundwater was present. It also <br /> requested RDM collect a grab groundwater sample from the soil boring. Based on the laboratory <br /> analytical results from this soil boring,the CVRWQCB would evaluate the data and determine if pilot <br /> testing was necessary, or whether the site may meet the State Water Resources Control Board's Low <br /> Threat Underground Storage Tank Case Closure Policy (LTCP) for No Further Action Required <br /> (NFAR)as a low-risk groundwater site. <br /> In addition to the revised scope of work discussed in the preceding paragraph, RDM was unable to <br /> install monitoring well MW-5 because the property owners (3201 East Main Street) failed to respond <br /> to RDM's numerous requests (both via mail and personal visits to the residence at 3201 East Main <br /> Street) for a right-of-entry agreement. RDM informed the CVRWQCB of the failure to get an <br /> approved right-of-entry agreement for MW-5. The CVRWQCB directed RDM to proceed with the <br /> other proposed work and based on the results of the groundwater analytical results for monitoring <br /> wells MW-4, MW-6 and MW-7, a future determination would be made as to whether MW-5 would <br /> need to be installed. <br />