SITE INFORMATION AND CORRESPONDENCE_FILE 2

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Page 1 of 2 Vicki McCartney [EH] From: Nuel Henderson [EH] Sent: Thursday, November 21, 2013 1:15 PM To: 'Diane Filippi' Cc: Joylyn Novacek; Dayna Nielsen;jbarton@waterboards.ca.gov; greg.gurss@cardo.com; david.daniels@cardno.com; Adrienne Ellsaesser[EH];Vicki McCartney [EH] Subject: RE: 4444 Pershing Avenue, Stockton California Ms. Filippi, The long-time caseworker for your site, Harlin Knoll, has retired, and as the new caseworker, Victoria McCartney, was not part of the meeting in question, I have reviewed the site status and notes to answer your questions. I have no recollection or notes and found no notes from other meeting participants from the regulatory community that indicate any statement or agreement that the site would be closed by the end of the year(2013); such a statement would not be consistent with past practices of our agency as we cannot foresee when events will actually take place or what the results will be. Our notes indicate the following: 1) We discussed previous remediation attempts and results for the site; 2) It was noted that the site does not pass the recently adopted Low Threat Underground Storage Tank Closure Policy (LTCP) by the California State Water Resources Control Board; 3) That one more remediation attempt should be made before considering the site for closure; and 4) An evaluation of insitu chemical oxidation (ISCO)would be conducted and submitted to the Environmental Health Department and to the Regional Water Quality Control Board within 45 days of the meeting for review. A work plan for ISCO dated September 9, 2013 was received by the EHD and was approved by Harlin Knoll on October 3, 2013, for injection of PerSulfOx to address impacted soil and groundwater. A requirement to proceed with the test is to file a Notice of Intent(NOI)with the RWQCB to inject the materials in order to get the testing and monitoring requirements needed by the RWQCB to approve the injections. To date the RWQCB has not received the NOI or any other communications regarding the proposed and approved scope of work on the site. Looking ahead, once Cardno ERI submits the NOI and the RWQCB approves the injections, the test can proceed, which in the work plan appears will take approximately a month to conduct. Harlin Knoll required one follow up monitoring event to evaluate the results, but to verify results and contaminant concentration trends at least two follow up monitoring events will be needed. The EHD anticipates this will take on the order of six months to accomplish, but again, the EHD has little control on the timing of the events or results. If the test is successful and the site appears to be ready for closure consideration the site must be reevaluated for closure, public notification and participation in the closure process must be provided, all monitoring and remediation wells installed as part of the site investigation and characterization must be properly destroyed and the waste products properly disposed before a closure letter can be issued; this may take approximately six more months to complete. If it appears that another injection round must be conducted or an additional monitoring event is needed, that will add to the time required to achieve site closure. All that being said, the EHD is interesting in getting your site to closure in the most rapid and cost-effective manner and will do what we as an agency can to aid you and expedite the process. As noted above, the new caseworker for your site is Victoria McCartney, and she can be reached at vmccartnev cDsicehd.com or at(209) 468-9852. 1 can be reached at nhendersonO-sicehd.com or at(209)468-3436. Please contact us if you have any additional questions or concerns. Nuel Henderson, PG From: Diane Filippi [mailto:dfilippi@spur.org] Sent: Tuesday, November 19, 2013 5:07 PM To:jbarton@waterboards.ca.gov; greg.gurss@cardo.com; Harlin Knoll [EH]; david.daniels@cardno.com; Nuel Henderson [EH] Cc: Joylyn Novacek; Dayna Nielsen 11/21/2013