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CLEARWATER <br /> G R O U P 1 i\ C <br /> Ennnanmentaf Serr ices <br /> 1 <br /> Petit's letter was written in response to an October 16, 1995 report by Lawrence <br /> ' Livermore National Laboratory (LLNL) titled Recommendations to Improve the <br /> CIeanup Process for California's Leaking Underground Fuel Tanks (LUFTs) <br /> ' The LLNL report also addresses the evaluation and cleanup of sites that cannot be <br /> classified as "low risk" In the report, the American Society of Testing and Materials <br /> ' (ASTM) Standard Guide for Risk-Based Corrective Action Applied at Petroleum <br /> Release Sites (E 1739-95) is recommended as standardized method to evaluate levels <br /> of risk posed by specific contaminated sites <br /> ' On the basis of the SWRCB recommendations, Clearwater recommends conducting <br /> a risk-based corrective action (RBCA) evaluation of the Conrady site prior to <br /> ' submitting the FS and CAP <br /> The followmz tasks are recommended <br /> ' d Submit a proposal for the ASTM (E 1739-95) Tier 1 and Tier 2 evaluations <br /> • Conduct a Tier 1 classification of the site, much of the site characterization has <br /> already been done, although a rece for sure needed to complete the Tier 1 <br /> evaluation <br /> ' • In the event that the Tier 1 corrective actionoals are notappropriate for this <br /> g <br /> site, proceed to a Tier 2 evaluation to determine site specific target levels (SSTLs) <br /> ' for the corrective action, Clearwater will communicate with the PHS/EHD <br /> regarding site-specific input parameters to be used in the evaluation <br /> • Submit a CAP and FS, if needed, on the basis of SSTLs obtained in the RBCA <br /> evaluation <br /> ' The completion of the RBCA evaluation will provide both Mrs Conrady and the <br /> San Joaquin County PHS/EHD with information required to effectively plan the <br /> most appropriate course of action <br /> D-101 1Q96 4 Apn1 18, 1996 <br /> 1 <br />