SITE INFORMATION AND CORRESPONDENCE 1995-2004

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Ms. Frances E. Anderson Page 2 Our differences on this point thus may be largely one of semantics. PG&E has no objection, philosophically,to describing those factors to be varied in the analysis as cleanup "levels", and considering the objective and goal given in your letter to be an unvarying starting point for the analysis. For the record, however, we should note that the U. S. Environmental Protection Agency Guidance for Conducting Remedial Investigations and Feasibility Studies Under CERCLA (OSWER Directive 9355.3-01), which sets forth guidance on implementing certain provisions of the National Oil and Hazardous Substances Pollution Contingency Plan (National Contingency Plan) (40 C.F.R. 300.61 et seq.), uses the terms"remediation goal" and "contaminant level" interchangeably, stating by parenthetic reference in Section 4.2.1, for example, that an acceptable contaminant level or range of levels for each exposure route is a preliminary remediation goal. Section 4.1.2.1 of that document provides that preliminary remediation goals should be developed which"...permit a range of treatment and.containment alternatives to be developed,"and that"...these preliminary remediation goals are reevaluated as site characterization data and information from the baseline risk assessment become available." It is clear from this National Contingency Plan guidance document that variations in goals may be the legitimate outcome of the feasibility study process. As you are aware, Section 3.1.1 of the Consent Order for the Stockton site (Docket No. HSA 90/91-008), as well as §25356.1(d) of the California Health and Safety Code, require that the feasibility study for this site be based on the National Contingency Plan. Regardless of the terminology used, PG&E is committed to performing the feasibility study analysis over the range of cleanup levels specified in our letter of June 6. We hope that the analysis will form the basis for thoughtful and unbiased judgments within the framework of the law and established policies. The Extent to Which Soil and Groundwater Have Been Characterized at the Site We (still) concur with the statement in your July 2 letter, excerpted from your letter of April 26, 1993, that"... one of the primary goals of the characterization work is to define the nature and extent of[the] contaminants of concern sufficiently to evaluate remedial action alternatives, including alternatives for a permanent remedial solution." The confusion which still exists on PG&E's part arises from differences in interpretation among PG&E, DTSC and the RWQCB as to which media have been characterized to that standard. For example, there remains the question as to your agency's position regarding the adequacy of the Area I soils investigation. The final Phase III Groundwater Investigation Workplan, approved by DTSC on August 18, 1993,contained a summary of the agreements reached at our May 27, 1993 meeting, including the agreement that"...soil has been adequately characterized to evaluate potential impacts to groundwater and to complete the FS, therefore no additional soil investigation is needed to define the extent of gas plant residue constituents." This agreement is made more formal in DTSC's October 21, 1993 letter to PG&E which approved the final Remedial Investigation & Risk Assessment report dated August 1993, and went on to direct that"...the additional