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Pacific Gas and Electric Company Environmental Services <br /> P.O.Box 7640 <br /> San Francisco, CA 94120 <br /> 415/973-7000 <br /> Direct Dial 415/973- <br /> April 29, 1996 Telecopy 415/973-9201 <br /> James L. Tjosvold, P.E. <br /> Chief, Site Mitigation Branch <br /> California Environmental Protection Agency <br /> r Department of Toxic Substances Control <br /> 10151 Croydon Way, Suite 3 <br /> Sacramento, CA 95827 <br /> Attention: Mr. Fernando Amador <br /> Dear Mr. Tjosvold: <br /> Re: Docket #HSA 90/91-08 - Stockton Former Manufactured Gas Plant Site <br /> Subject: Status of Revised Project Schedule - Soil Operable Unit Feasibility Study (OUFS) <br /> Attached is the most recent project schedule (as forwarded to you on March 13, 1996) for the <br /> Stockton Former Manufactured Gas Plant Site. The final Soil OUFS schedule will require <br /> revision due to issues concerning the final Soil OUFS and will continue to be revised pending <br /> an agreement on the remedial action objectives and goals for groundwater. <br /> The following is a summary of the most recent activities on the Soil OUFS: <br /> • The report"Evaluation of Potential Groundwater Impacts from Residues in Soil' was <br /> submitted to you on March 13, 1996. <br /> • Due to scheduling difficulties, the conference call to discuss the above report took place on <br /> April 3, 1996 instead of(as scheduled) on March 27, 1996. <br /> • PG&E initially planned to include the results of this report in the final Soil OUFS Sections <br /> 4 and 5 to be submitted to you on April 24, 1996. However, this submittal was postponed <br /> when PG&E received comments from DTSC on April 11,1996 requesting further <br /> VLEACH modeling work. Further, on April 25, 1996 DTSC forwarded comments from <br /> the RWQCB (dated April 18, 1996) on the soil report which raise significant questions <br /> regarding the modeling results. <br /> Faced with apparently conflicting sets of agency comments, PG&E believes it is premature to <br /> incorporate the results of the soil modeling report into the final Soil OUFS at this time. More <br /> importantly, since the agency comments clearly point out the dependence of soil remedy <br /> effectiveness on the eventual objectives and goals for groundwater, a question remains at this <br /> time as to how to evaluate a soil remedy without clear agreement on the groundwater <br /> objectives and goals. It should be noted that PG&E presented the groundwater objectives and <br /> goals in a letter to DTSC dated August 17, 1995. As you are aware, PG&E has spent a <br />