Send this letter Clean up the Toxic Waste
at Marinwood Plaza
before the end on business on Monday, February 22, 2016 to save our community from an inadequate toxic waste cleanup. It is important that every concerned citizen participate. It sends a clear message that we will only accept a full remediation solution rather than allow toxic waste to remain in the soil for decades.
Feel free to leave a message if you have questions. Thank you for supporting our community.
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Ralph Lambert
Regional Water Quality Control Board re: (#SL0604185908)
San Francisco Bay Region
1515 Clay St., Suite 1400
Oakland, CA 94612
Dear Directors of the Regional Water
Quality Control Board & Mr Lambert:
We are depending on
you to do the right thing for our community and the environment.
I urge the Regional
Water Quality Control Board(RWQCB) to reject
in entirety the Remedial Action Plan (RAP) put forth by Marinwood
Plaza II , LLC and Geologica for Prosperity Cleaners, 187 Marinwood Ave,
San Rafael, CA 94903 (#SL0604185908) on December 29, 2015. The
Remedial Investigation is incomplete, the proposed action plan is
technically and scientifically inadequate and the plan does not meet EPA’s own CERCLA
guideline or meet the terms of the RWQCB Executive order of February 14,
2015. The action plan has no start date and is only contingent up on redevelopment.
This is clearly not consistent with the terms or intent
of the Executive Order. The RAP should be rejected until it complies with the Order and
describes complete remediation of the Site to include Marinwood Plaza, Silviera
Ranch, Casa Marinwood.and the eastern & western boundaries of Marinwood
Ave.
We strongly urge
an Interim Remediation Plan to commence at the earliest possible date
or by April 1, 2016 to aggressively remove the two or more toxic hotspots on
the site to a depth of 35’ and a diameter that encompasses all known
contaminated soil of at least 75’ or more.
No active remediation has occurred
since 2011. We demand full, aggressive remediation of the toxic hotspots at the Marinwood Plaza site immediately while
methods for remediating offsite contamination, whether soil vapor or
groundwater, are identified for timely implementation in an approved RAP. Partial solutions are unacceptable.
We concerned citizens of Marin
demand a full remediation of Marinwood Plaza (#SL0604185908)
that will not imperial the environment and community health for decades
to come.
Please
respond to the following questions:
Soil:
1.
Previously
it’s been disclosed that contamination at the source areas extends to a depth
of at least 35 feet. The RAP proposes
excavating soil to a depth of only 12 feet beneath the building and leaving the
remaining contamination in place.
What
happens to the deeper contamination that you propose to leave? Won’t that continue to contaminate
groundwater, as it’s doing now, and as noted in the Board Order?
2.
Soil
was sampled at only a few locations at the Eastern Hot Spot to verify soil
contamination after treatment in 2011.
Why are you not proposing to excavate in this area to verify that soil
contamination above cleanup standards is not present?
3.
The
RAP estimates that approximately 45 cubic yards of soil will be excavated based on very limited information. What will happen if the soil contamination
turns out to be much more extensive?
Soil Vapor:
1.
We
understand that contaminated soil vapor is moving preferential pathways along buried utility lines. When you tested for soil vapor in the Casa
Marinwood neighborhood you located the
underground utilities but avoided them during your testing. If you were concerned about damaging utility
lines as you claimed, why didn’t you use passive soil vapor sampling that has
commonly been used for investigations at other sites?
2.
Absolutely
no contaminated soil vapor was reported at Casa Marinwood, which is not
surprising because you did not sample the contaminant pathways where the vapor
is moving. When will you conduct a valid
soil vapor investigation at Casa Marinwood?
3.
Once
you’ve blocked the pathways for soil vapor at the Site, where will the
contaminated soil vapor that is present adjacent to Casa Marinwood go; into the
houses?
Groundwater:
1.
Why
did you submit a feasibility study that does not follow EPA guidance as
required by the Board Order?
2.
Why
do you think it’s reasonable to develop a remedial action plan when you haven’t
yet completed the remedial investigation?
3.
Why
haven’t you installed any monitoring wells east of Hwy 101?
4.
Why
have you not conducted any groundwater monitoring east of Hwy 101?
5.
Why
was MNA the only remedial approach considered in the feasibility study?
6.
How
can NMA be seriously considered when the extent of groundwater contamination is unknown?
7.
How
can you possibly evaluate whether the groundwater plume is stable or shrinking
if you don’t know how far it goes?
8.
Given
that dry cleaning fluid (PCE) is present a considerable distance east of Hwy
101, what evidence exists that supports the complete breakdown of PCE to
non-toxic compounds?
9.
Why
were remedial approaches that are commonly used to cleanup VOC contamination in
groundwater at sites in Silicon Valley not evaluated in the feasibility study?
10. Why
do you think it’s OK to contaminate millions of gallons of valuable drinking
water and then walk away without cleaning it up?
Please send
your responses to Bill McNicholas, Chairman of the “Cleanup Marinwood Plaza Now
,” Citizen Oversight Committee : billmcn@pacbell.net ,
murphy1978y@comcast.net , stephennestel@gmail.com