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James L. Tjosvold, A • <br /> October 5, 1999 <br /> Page 6 <br /> the potential formation of more toxic partial degradation products, such as <br /> polychlorinated dibenzo-dioxins or furans. Waste products from the destruction are <br /> carbon dioxide gas and water vapor. The use of clean-burning natural gas as fuel <br /> significantly reduces hydrocarbon releases from the dryer. Thermal dryers/thermal <br /> oxidizers are in use in similar applications throughout California. <br /> Elimination of the stockpiles before the onset of the rainy season is a prudent step from <br /> both the environmental and public acceptability standpoints. Despite PG&E's imposition <br /> of runoff control measures, maintaining a large stockpile onsite throughout the rainy <br /> season always increases the potential for soils, and contained contaminants,to be carried <br /> offsite in runoff. Delays in eliminating the stockpiles will postpone installation of the site <br /> cap, further increasing the potential for rainfall intrusion through the post-remedial <br /> amounts of residues which remain on site. <br /> The inability to treat wastes on site would result in the shipment of approximately 1600- <br /> 1700 cubic yards of waste to a RCRA Subtitle C hazardous waste facility, resulting in an <br /> increase in local truck traffic brought about by the necessity to use smaller shipping <br /> containers which can be loaded into railcars. <br /> PG&E supports the community's right to know of the proposed modifications to the <br /> Stockton site remedy, and we are committed to providing full public notice of the <br /> proposed modifications, consistent with regulations governing the federal CERCLA <br /> program. We will develop an Explanation of Significant Differences document, with <br /> supporting information,which will reside in the local information repository and in <br /> DTSC files, and we will publish a notice that summarizes those differences, and the <br /> reasons for such differences, in a major local newspaper. <br /> Finally, it bears mentioning that PG&E has only to complete the management of these <br /> soils to complete its soil remediation at the Stockton site,which has resulted in the <br /> excavation and removal of more than 15,000 cubic yards of soil since the inception of <br /> field work on May 18. PG&E appreciates DTSC's support throughout the Stockton <br /> former MGP remediation project. Thank you for your consideration of this request to <br /> modify the remedy at the site,which we believe represents a more expeditious, cost- <br /> effective and environmentally responsible approach. If you have any questions <br /> concerning this request, or wish to receive additional information regarding our proposal, <br /> please do not hesitate to contact me at(415) 973-7601 or Patricia Sullivan, the PG&E site <br /> manager, at(415) 973-6254. <br /> Sincerely, <br /> e <br /> ,� �� <br />