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6633 Pacific Ave <br /> Page 5 <br /> Technology Screening <br /> PHS/EHD does not agree that remediation monitoring/data collection, institutional <br /> controls or drilling/well installation are effective remedial alternatives. Data <br /> collection and well installation are components of the investiation and verification <br /> phases. <br /> Recommended Remedial Alternative <br /> Natural Attenuation <br /> This is not a viable alternative primarily because at this time there is no legal <br /> way in which institutional controls can be implemented. Furthermore, the use <br /> of this alternative has not been shown to be effective in reducing groundwater <br /> plumes of this size or concentration to the appropriate cleanup levels. <br /> Alternative Evaluation <br /> The discussion regarding the actual effectiveness of Alternative 2 (SVE/Air <br /> Sparge) and its relation to the presence of the VOCs beneath the site was <br /> confusing. It was unclear whether effectiveness would be reduced because <br /> of chlorinated hydrocarbons' interference with the remediation or that it <br /> would take longer to remediate the chlorinated hydrocarbons also. <br /> As it is infeasible to enforce institutional controls, the selection of natural <br /> attenuation for groundwater remediation is unfounded and the effectiveness <br /> of this remedial alternative has not been demonstrated. <br /> Summary <br /> PHS/EHD has provided information with which you should be better able to prepare and <br /> submit an acceptable CAP. Should you have any questions, or wish to discuss PHS/EHD <br /> comments further, please contact me at (209) 468-0337. <br /> Donna Heran, REHS, Director <br /> Environmental Health Division <br /> %rw ct--� <br /> Mary Meays, Senior REHS Diane . Hinson, REHS <br /> Site Mitigation Unit Supervisor <br /> MM/6633PAC <br /> cc: CVRWQCB, Elizabeth Thayer <br /> Lincoln Properties, Wilbur H. Smith, 374 Lincoln Center Stockton CA 95207 <br /> xC: <br /> Pacific Environmental, Steven Krcik <br />