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r -- <br /> Vicki McCartney [EH] <br /> From: Jim Barton obarton@waterboards.ca.gov] <br /> Sent: Wednesday, December 22, 2010 6:23 AM <br /> To: Nuel Henderson [EH] <br /> Cc: Adrienne Ellsaesser[EH]; Vicki McCartney[EH] <br /> Subject: Re: 2969 E Loomis Road <br /> Hi Nuel, <br /> I think the Fund's recommendation is not protective of water quality, since there is an <br /> increasing trend of TPHd impacts to water .quality if you disqualify the suspect lab. data: <br /> And there are definitely threats to nearby domestic wells. I concur to. sampling those <br /> domestic wells. and putting them on notice that the State Water Board has recommended <br /> closure. They didn't even get the residual mass in soil correct, underestimating it by <br /> 60,000 lbs. As for mobilizing the TPHd into groundwater, they would need a contingency <br /> plan to stop. it from impacting the wells. I. will .speak with my management to see if there <br /> is something else we can do, and get back to you. <br /> By the way, Sarale Farms/AEG needs to contact me concerning injecting RegenOX at their <br /> site. <br /> Thanks. <br /> i <br /> Jim Barton <br /> i <br /> >>> "Nuel Henderson [EH] " <nhenderson@sjcehd.com> 12/21/2010. 4 :25, PM >>> <br /> Jim, <br /> The CUP 5-Year. Review has recommended the Marci 's. Diesel site for closure. consideration. I <br /> had prepared a letter to contest that recommendation., but inadvertently didn't send it. <br /> The RP. and consultant <br /> (GTI) upon receiving the 5-yesr review recommendation for closure desire to go with that. <br /> rather than continue with remedial pilot testing. I called and discussed the site with <br /> Kirk and submitted my unsent letter. <br /> He and Bob Trommer considered it and reissued their recommendation - again for closing the <br /> site. <br /> Attached are my letter, the new 5-year letter, and the email text from Kirk. Although I'd <br /> like to give a shot at an aggressive form of. ISCO. as a final. attempt to. reduce the TPHd <br /> mass, I'm afraid the CUP will not. pay for it in this difficult and changing environment. I <br /> also wonder if such an attempt may mobilize some hydrocarbon, potentially impacting wells <br /> not currently impacted. I don't. see a good path to follow here. I. don't want to contest <br /> this further with the CUP if I don't have a good technical justification, and they're not <br /> buying what I have at present. . <br /> Vicki and I will be asking.for a round of. sampling all. the adjacent water supply wells to <br /> assess for TPHd in the waterroduced. If there is no impact and I don <br /> � p t came up with a <br /> good technical justification and potentially effective remedial option, I'm thinking of, <br /> starting the closure process, part of which will be makingsure the adjacent sites. owners <br /> are aware of the site circumstances and have an opportunity to comment on the impending <br /> closure. I'll also. be using the expressed professional opinions of the CUP that <br /> essentially makes the site a low-risk site. <br /> Thoughts? <br /> I <br /> 1 <br />