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Mr. Thomas Bauhs -2 - 3 May 2005 <br /> Ms. Kitty Walker <br /> Joaquin Valley Air Pollution Control District has requested this sampling of the discharge <br /> to the atmosphere from the dual phase extraction system and including the monitoring of <br /> extraction wells is appropriate. In regards to the HRA, some PAHs have potential to <br /> migrate to indoor air via vapor intrusion and are included in DTSC's vapor intrusion <br /> guidance (DTSC, 2004. Guidance for the Evaluation and Mitigation of Subsurface Vapor <br /> Intrusion to Indoor Air. 15 December 2004). Method TO-13 is recommended for PAHs; <br /> however, some PAHs, such as naphthalene, are poor candidates for Method TO-13. <br /> Therefore TO-15 is recommended for naphthalene. <br /> 3. Due to nomenclature problems regarding the extraction wells and proposed soil vapor <br /> - monitoring points in the Work Plan and Letter, the L&M OU does include a soil vapor <br /> monitoring point west of the furthest extraction well. HERD'S memorandum identified an <br /> area between soil vapor locations SV-4 and SV-7 for a soil vapor monitoring point <br /> location west of the soil vapor extraction system. The L&M OU needs to propose a soil <br /> vapor monitoring point to evaluate the radius of influence west of the furthest soil vapor <br /> extraction well. <br /> 4. Ina 1 March 2005 teleconference call that was documented in a 9 March 2005 DTSC <br /> memo, EarthTech agreed to: <br /> • communicate with ChevronTexaco/ConocoPhillips (CT/CP) regarding the call; <br /> • provide all interested parties with CT/CP's position regarding addressing DTSC's <br /> 8 February 2005 synopsis of comments to the HRA and submittal of a final HRA; and <br /> • communicate whether the HRA boundary as agreed to in the VCA is still in effect. <br /> These issues have not been addressed. The L&M OU must provide responses to the <br /> above bulleted items. <br /> On 18 April 2005, Regional Board staff spoke with Mr. Rusty Benkosky of SECOR regarding <br /> comments that need responses by the L&M OU. Although the Letter requested that the <br /> comments from the attached letters be incorporated into a revised work plan, it was apparently <br /> unclear which comments needed responses by the L&M OU. Therefore,because of the number <br /> of parties involved with the site and volume of comments provided on submittals,Regional <br /> Board staff letters will include which comments need responses. Based on this explanation,by <br /> 20 May 2005, the L&M OU needs to provide a revised work plan that addresses comments#1 <br /> through#4 above, all the comments in HERD'S 3 March 2005 Memorandum from <br /> Ms. Karen Dibiasio to W. Jerry Lile and comments 1, 3, 4, 9, 12, and 13 submitted in GSE's <br /> 11 March 2005 letter. These letters were previously provided and are therefore not attached. If <br /> you have any questions,please contact me at (916) 464-4719 or dlewis@waterboards.ca.gov. <br /> DEVRA LEWIS <br /> Environmental Scientist <br /> Attachment <br /> cc: See Page 3 <br />