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Mr. Ken Gillies • • <br /> Gillies Trucking <br /> 3931 Newton Road, Stockton <br /> Page 2 of 2 <br /> would be appropriate. The EHD considers wells in the core area, near the down-gradient <br /> extent of the dissolved plume and sentinel wells to be the most critical for frequent <br /> monitoring; wells in the up-gradient and cross-gradient directions that are commonly <br /> 'non-detect' can be sampled less frequently. The sampling strategy should be to <br /> document concentration trends representative of the dissolved plume mass and to <br /> detect expansion and/or contraction of the dissolved plume. Submit a proposed <br /> sampling schedule that meets these monitoring goals to the EHD by 17 December 2007. <br /> Excavation was dismissed as highly disruptive to your site operation and as unlikely to <br /> effectively address impacted soil between 40 and 60 feet below surface grade, where <br /> the bulk of the contaminant mass is inferred to reside. SVE, bioventing and injection of <br /> oxidizing agents were considered to hold more potential for your site. The EHD <br /> recognizes that it is unlikely that your site can be cleaned up to pristine conditions, but <br /> the methods discussed (excavation excepted) may individually, or in combination, <br /> effectively reduce the contaminant mass, toxicity and mobility sufficiently enough to <br /> achieve favorable leach test results and a low-risk closure. <br /> Evaluate the remedial methods noted above, and any others you or your consultant <br /> believes may be applicable to your site, to address impacted soil and submit a report <br /> with recommendations to the EHD by 07 January 2008. <br /> Questions or comments may be directed to Nuel Henderson by mail (address on letter <br /> head), or by telephone at (209) 468-3436. <br /> Donna Heran, REHS, Director <br /> Environmental Health Division <br /> Nuel C. Henderson, Jr., PG Marg�agorio, REHS <br /> Engineering Geologist Program Coordinator <br /> Unit IV- Site Mitigation Unit IV— Site Mitigation <br /> cc: James L.L. Barton, PG —CVRWQCB <br /> Victor Cherven, PG — UEC <br /> Clyde Hebbron, PG - UEC <br />