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Pacific Gas and Electompany 77 Beale Street,Room 2456-1324A - Robert C. Doss, RE <br /> San Francisco,CA 94105 Director <br /> 415/973-7601 Site Remediabor. <br /> Fax 415/973-9201 Environmental Services \ <br /> Internet RLDL@pge.com <br /> October 5, 1999 It"d ng d&dreg <br /> P.O.Box 7640 <br /> San Francisco,CA 94120 <br /> James L. Tjosvold, P. E. <br /> Chief, Site Mitigation Branch <br /> i <br /> California Department of Toxic Substances Control <br /> 10151 Croydon Way <br /> Suite 3 <br /> Sacramento, California 95827-2016 <br /> Attention: Mr. Fernando Amador <br /> Re: Request for Determination of and Approval to Implement a Significant <br /> Change to Remedy—PG&E Stockton Former Manufactured Gas Plant <br /> Site (Docket#HSA 90/91-08) <br /> Dear Mr. Tjosvold: <br /> PG&E hereby requests approval to implement the change described below to the <br /> approved remedy for the Stockton former manufactured gas plant ("MGP") site located at <br /> Church and Center Streets in Stockton, California. PG&E believes that the proposed <br /> change would constitute a"significant change to a remedy" within the meaning of that <br /> phrase as set forth in applicable state and federal guidance, for the reasons given below. <br /> Background <br /> By letter dated April 2, 1998, the California Department of Toxic Substances Control <br /> ("DTSC") approved the final Remedial Action Plan—PG&E Stockton Former <br /> Manufactured Gas Plant Site (the"RAP"). The remedial action for groundwater specified <br /> in the RAP is monitored intrinsic bioremediation in each of the three groundwater zones <br /> underlying the site. The soil remedial option specified is excavation of soil in nine areas, <br /> including three.source areas, and management of soils as follows: <br /> • Excavated clean soil would be reused onsite as backfill; <br /> • Soil and residues containing chemicals below hazardous waste threshold <br /> concentrations would be disposed of at a Class II landfill; and, <br /> • Residues that meet the criteria for a hazardous waste under federal Resource <br /> Conservation and Recovery Act("RCRA") regulations would be reused <br /> through onsite incorporation into asphalt road base. <br /> By letter to your agency dated September 21, 1998, PG&E requested that the soil <br /> management procedures set forth in the approved RAP be modified to reflect changes in <br />