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4648 Waterloo <br /> Page 2 <br /> Your correspondence stated that any detailed cost presentation would constitute a bid by Advanced <br /> GeoEnvironmental and place them at a disadvantage in the subsequent bidding process. The <br /> California Code of Regulations, Title 23, Division 3, Chapter 16 Section 2725(f) states that: <br /> The responsible party shall conduct a feasibility study to evaluate alternatives for remedying <br /> or mitigating the actual or potential adverse effects of the unauthorized release. Each <br /> alternative shall be evaluated for cost-effectiveness and the responsible party shall propose <br /> to implement the most cost-effective correction. <br /> Further Section 2725(f)(2) states that: <br /> For sites where the unauthorized release affects or threatens waters with current or <br /> potential beneficial uses designated in water quality control plans, the feasibility study shall <br /> also identify and evaluate at least two alternatives for restoring or protecting these <br /> beneficial uses. <br /> The corrective action regulations were designed to minimize the costs associated with remediating <br /> contamination resulting from releases of contaminates to the environment. With the general cost <br /> estimates which were included in the corrective action plan and the comments of Advanced <br /> GeoEnvironmental, still do not provide information to demonstrate that vapor extraction is more cost <br /> effective. Please note that costs associated with vapor extraction ranged from $85,000 to 150,000 <br /> per year with no estimate of conceivably how long it will take using the vapor extraction well and <br /> MW1. An estimate which was included in supplemental information for excavation was between <br /> $150,000 and $200,000. Clearly, the effectiveness of these two remediation methods cannot be <br /> demonstrated with the information provided. <br /> With regards to the necessity of groundwater remediation, please note that concentrations observed <br /> in MW1 have not been decreasing and in fact have been increasing. PHSIEHD has indicated already <br /> that groundwater remediation is required by regulation and that the decrease observed in MW2, <br /> MW3, and MW4 may well be due to temporary dilution rather than remediation. <br /> PHSIEHD did include the statement "Since hydrocarbons were generally detected to 45 feet below <br /> grade, the depth of the vapor extraction well, VW1, will be reduced from 72 feet to 47 feet by <br /> filling the bottom 25 feet of the well with some material" as concurrence that the existing <br /> construction of VW1 would not be proper for use as a vapor extraction well. <br /> PHSIEHD looks forward to the submittal of the addendum which was requested and which <br /> hopefully will provide all the information necessary to evaluate the remedial alternative which you <br /> have selected. <br /> If you have any questions, please contact Mary Meays at (209) 468-0337. <br /> Donna Heran, RENS, Director <br /> Environmental Health Division <br /> Mary Meays, Senior RENS Diane M. Hinson, RENS <br /> Site Mitigation Unit Supervisor <br /> MM14648.WAT <br /> cc: Elizabeth Thayer, CVRWQCB <br /> cc: George Lockwood, SWRCB <br /> cc: Bob Marty, Advanced GeoEnvironmental <br />