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`� California Regional Water Quality Control Board <br /> �\% Central Valley Region <br /> Robert Schneider,Chair Gray Davis <br /> Winston H.Hickox <br /> Secretaryfor Sacramento Main Office Governor <br /> Environmental Internet Address: http://w .swrcb.ca.gov/twgcb5 <br /> Protection 3443 Reader Road,Suite A,Sacramento,California 95827-3003 <br /> Phone(916)255-3000•FAX(916)255-3015 M <br /> 22 August 2002 <br /> AUG 2 6 2002 <br /> Mr. Brian Miller ENVIRONMENT HEALTH <br /> PERMIT/SERVICES <br /> Agrium <br /> 1220 Potter Drive <br /> West Lafayette, IN 47906 <br /> REVIEW OF REPORTS, WESTERN FARM SERVICE, STOCKTON, SAN JOAQUIN COUNTY <br /> On 9 December 1999, Office of Environmental Health Hazard Assessment (OEHHA)provided <br /> comments on the June 1999 Draft Human Health Risk Assessment and Risk-Based Cleanup Level <br /> Development Report(HRA) submitted by Newfields on behalf of Unocal Corporation(Unocal) for the <br /> former PureGro agricultural chemical facility at 1905 North Broadway Avenue in Stockton(site). On <br /> 7 July 2000,Unocal submitted Newfield's Response to Comments Draft Human Health Risk Assessment <br /> and Risk-Based Cleanup Level Development Report(Response to Comments),which OEHHA has <br /> reviewed and provided comments in the attached 31 July 2002 memorandum. Since the submittal of the <br /> HRA and Response to Comments, Western Farm Service (WFS) has taken over environmental liability <br /> for the site from the Unocal Corporation. <br /> We have reviewed the following reports submitted by Sierra-Pacific Group on behalf of WFS for the <br /> site: <br /> 29 July 2002 Remedial Action Plan for Remediation of Soil(RAP); <br /> 29 July 2002 Feasibility Study for Remediation of Ground Water(FS); and <br /> • 30 July 2002 Second Quarter 2002 Quarterly Monitoring Report(Report). <br /> The RAP proposes to pave the site and inject Hydrogen Releasing Compound (HRC®) into vadose zone <br /> soils in the area of the former ponds. The FS proposes a pilot-scale study to inject HRC® into <br /> groundwater and vadose zone soils. Other remedial alternatives evaluated in the FS were monitored <br /> natural attenuation, extraction with direct discharge to a publicly owned treatment works (POTW), <br /> extraction with pretreatment for pesticides prior to POTW discharge, and extraction with biological <br /> treatment. The Report discusses the groundwater level data collected in June. We have no comments on <br /> the Report. <br /> Based on OEHHA's 31 July 2002 comments, there are potential health concerns at the site, and the <br /> extent of soil pollution is not defined. Therefore, WFS needs to submit a work plan to collect additional <br /> California Environmental Protection Agency <br /> pia Recycled Paper <br /> The energy challenge facing California is real. Every Californian needs to take immediate action to reduce energy consumption. <br /> For a list of simple ways you can reduce demand and cut your energy costs,see our Web-site at http://w .swrcb.ca.gov/mgcb5 <br />