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Gurpal S Sidhu 23 January 2009 <br />Waterloo Feed and Fuel <br />Page 2 of 3 <br />3032 E. Waterloo Road, Stockton, CA <br />If the plume of dissolved methyl tert-butyl ether (MTBE) impacting WFS MW-20B <br />is from your site, the plume extends nearly halfway to a California Water Service <br />municipal water well near Filbert Street and Cherokee Road; it is extremely <br />important to protect this well and other water supply wells in the area from <br />contamination from your site. <br />Groundwater on your site has been under interim remediation by groundwater <br />extraction (GWE) since May 2003, and as of September 2008, the GWE system <br />had removed an estimated 10,663 pounds of total petroleum hydrocarbons <br />quantified as gasoline (TPH-g), 595 pounds of benzene and 1,150 pounds of <br />MTBE, which the EHD believes to be unprecedented for an unauthorized release <br />from a hydrocarbon fuel UST in San Joaquin County, yet the extremely high <br />contaminant concentrations in groundwater have hardly dropped at all, which <br />indicates a high transfer rate of contaminants from soil to groundwater. <br />Intuitively, to more effectively remediate impacted groundwater the impacted soil <br />must also be remediated. <br />Soil has been under interim remediation by SVE since December 2006, and as <br />of September 2008, an estimated 28,986 pounds of TPH-g had been removed, <br />demonstrating the effectiveness of SVE to remove the contaminants from soil, <br />but the relative lack of response in contaminant concentrations in groundwater <br />demonstrates that much more contaminant mass must be removed to begin to <br />significantly benefit groundwater quality; reducing the operational time of the <br />SVE unit by 75% obviously will not increase the effectiveness of the remedial <br />effort. <br />For the reasons noted above, the EHD cannot approve 'pulsing' the SVE system for <br />one week per month as under that circumstance, the remedial effort will not be <br />adequate to be protective of either groundwater quality or of the sensitive receptors (the <br />California Water Service wells) in the area. The EHD is sensitive to the current <br />economic situation and will do what it can to ease the financial burden on you as much <br />as possible and still be effectively protective of the groundwater resource; to that end <br />the EHD will consider the following if proposed by your consultant: <br />A reduction of groundwater sampling requirements during the quarterly <br />groundwater monitoring events to reduce field time and analytical costs. The <br />proposed schedule should be sufficient to detect additional migration of the <br />dissolved plume or a change in plume migration direction, identify any impending <br />threat to sensitive receptors, and to evaluate the effectiveness of the remediation <br />systems operating on your site. <br />Modification(s) to the remediation systems that will result in an increased <br />contaminant mass recovery. <br />If cost savings can be realized, a reduction in reporting requirements as long as <br />essential information is provided to the EHD in a timely manner. The EHD would <br />be satisfied with hard copies that report procedures and results limited to the <br />quarter being reported and cumulative quantities related to the remediation <br />Meeting Summary and Directive Letter 0109