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mas Bauhs • 2 • J <br /> Ms. Kitty Walker 11 July 2005 <br /> J <br /> L&M OU must not conduct the start-up and shake-down of the SVE until it obtains further <br /> written approval from Regional Board staff. <br /> Regional Board staff request that L&M OU and its consultants participate in monthly technical <br /> meetings for the purpose of discussing site cleanup including any implemented remedies and <br /> progress. Therefore, we propose the first of these meeting to be held at 9:00 A.M. on <br /> 18 August 2005 at our Regional Board office. Further, Regional Board staff request that <br /> L&M OU complete a comprehensive schedule of all site activities and that this schedule be <br /> updated on a monthly bases for our scheduled meetings. <br /> 3. Regional Board staff concurs with the strategy contained in the Work Plan and L&M OU may <br /> proceed to implement this work including the installation of the vapor probes as scheduled for <br /> 13 July 2005. <br /> 4. The 7 July Response Letter provides an additional comment that states, "Pursuant to the <br /> settlement between the L&M OU Group and the RDA, the L&M OU Group will remediate soil <br /> and groundwater at the L&M OU site...Based on this settlement agreement, the remediation of <br /> soil and groundwater beyond residential standards is the responsibility of the RDA." Cleanup <br /> goals are established with consideration to human health, the environment and designated <br /> beneficial uses of the waters of the state. At future meetings, Regional Board staff will be happy <br /> to discuss the process by which cleanup goals are set. <br /> 5. In 13 June Review Letter contains a comment regarding the proposed location of the soil vapor <br /> extraction wells that includes suggested alternative coordinates. However,no supplementary <br /> information is included, such as a figure depicting the proposed modifications, making it difficult <br /> to consider this comment in a timely fashion. hi order to accomplish a timely reply to work plans <br /> submitted by the L&M Operable Unit Group, Regional Board staff are available to meet with the <br /> RDA and its consultant GSE on a routine bases. The soil vapor sampling protocol will assist in <br /> evaluating remedial effectiveness and the protocol for vapor extraction can be modified in the <br /> future. <br /> 6. The 13 June Review Letter states, "The rationale used for not placing vapor points along this <br /> perimeter is unfounded in that remedial actions will not be approved by the RDA ...The resultant <br /> remedial action at the Unocal OU may not include soil excavation as proposed previously by <br /> Unocal." This statement is obviously on behalf of the RDA as an agency, and not as a joint <br /> responsible party and the RDA does not include a rationale for excluding a remedial option at <br /> this point in the planning process. Removing this remedial strategy from consideration may <br /> result in an in-situ treatment process and a much longer time period necessary to reach remedial <br /> goals. Again, additional vapor points may be installed once a comprehensive cleanup plan is <br /> approved. <br /> 7. The 13 June Review Letter also states,"Evaluation of the proposed number and location of the <br /> APS V vapor points will be easier upon collection of data from the HHRA." Waiting for HHRA <br /> sampling will only prove to delay implementation of source removal. The longer pollutant <br />