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California Fuel Station � <br /> Page 2 of 3 <br /> The TPH-g and BTEX concentrations are often very similar in the three zones and <br /> generally show the same fluctuation through time; for instance the fourth quarter <br /> 2006 analytical results for TPH-g at MW-13A, MW-13B, and MW-13C were 260 <br /> µg/1, 290 µg/1, and 220 µg/l, respectively. This seems unusual as the upper and lower <br /> well intervals have 45 feet of vertical separation and fine-grained units occur between <br /> the wells. This suggests that there may be communication in between the depth <br /> intervals. Since there are no other data points in the deeper zone, the vertical and <br /> lateral extent of impacted groundwater cannot be considered to be defined, and <br /> therefore the EHD does not consider this site ready for closure. <br /> • Proposed tracer test. In the QR, AGE recommends that a tracer test utilizing <br /> fluorescent dye and/or food grade coloring dye be performed to evaluate the integrity <br /> of MW43A, MW-13B, and MW-13C. EHD directs that a workplan be submitted to <br /> accomplish this by November 16, 2007. Once the integrity of this well has been <br /> evaluated, the implications regarding the vertical extent of your plume should be <br /> evaluated. Central Valley Regional Water Quality Control Board (CVRWQCB) must <br /> give approval before any substances can be injected into groundwater. <br /> • Proposed CPT„borings. Based on the deep groundwater impact at MW-13A, <br /> MW-13B, and MW-I3C, AGE recommends utilization of three cone penetration test <br /> (CPT) soil borings to depths as great as 150 feet bsg to characterize of soil and collect <br /> grab ground water samples on-site in the vicinity of MW43, in the city right-of-way <br /> near MW-4, and in the apartment complex located towards the northeast. At this time <br /> the EHD can not concur with this recommendation, however, if the results of the <br /> tracer test show that the integrity of MW-13A, MW-1313, and MW-13C is sound and <br /> the deeper aquifer zones are impacted, the proposed investigation well be justified. <br /> • Proposed soil vapor samples. As noted in the QR, the CVRWQCB is requiring <br /> evaluation of Environmental Screening Levels (ESLs), California Human Health <br /> Screening Levels (CHHSLs) and the potential for vapor intrusion into buildings prior <br /> to closure consideration. AGE stated that a vapor intrusion evaluation is warranted at <br /> this site and a workplan should be prepared to collect at least two to three 5-ft soil <br /> vapor samples as noted in Figure 2 in the QR. Submit a workplan to collect the soil <br /> vapor samples and a technical justification for the selected sampling points to the <br /> EHD by November 16, 2007. <br /> • Proposed_installation of a new SVE well. In the QR, AGE recommended installation <br /> of at least one additional SVE well north of AW-2 (shown in Figure 2 in the QR) to <br /> ensure recovery of air-sparged contaminants. Before approving installation of <br /> additional SVE wells or reinitiating the SVE/IAS system operation, the EHD believes <br /> additional monitoring data should be obtained and evaluated to justify such actions. <br /> The EHD would approve advancement of a confirmation soil boring in the proposed <br /> SVE well location to evaluate the effectiveness of the recent SVE/IAS operation; if <br /> significant soil contamination is encountered, the boring could be converted to an <br />