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' J <br /> c OF CALIFORNIA—CALIFORNIA ENVIRONMENTAL PROTECTION AGENCY PETE WILSON, Goretmr <br /> DEPARTMENT OF TOXIC SUBSTANCES CONTROL <br /> REGION 1 <br /> 10151 CROYDON WAY, SUITE 3 ` <br /> SACRAMENTO, CA 95827-2106 - <br /> (916) 255-3737 <br /> December 26 , 1995 <br /> Mr. Robert Doss, P.E. <br /> Project Manager <br /> Pacific Gas & Electric Company <br /> Environmental Services <br /> 77 Beale Street, Room F-1636 <br /> San Francisco, California 94106 <br /> PACIFIC GAS & ELECTRIC, STOCKTON SITE <br /> Dear Mr. Doss: <br /> The Department of Toxic Substances Control (DTSC) and <br /> Regional Water Quality Control Board (RWQCB) have reviewed the <br /> Draft Soil Operable Unit Feasibility Study (FS) Workplan dated <br /> November 1995, prepared for the PG&E Stockton former manufactured <br /> gas plant site. As discussed in our November 30, 1995 meeting, <br /> DTSC and the RWQCB have identified several comments that need to <br /> be addressed in a revised FS Workplan. Following are DTSC <br /> comments and enclosed are RWQCB comments that must ue addressed <br /> prior to the FS Workplan being approved: <br /> 1. The FS Workplan has failed to define a criteria to establish <br /> soil cleanup levels that would be protective of groundwater. <br /> In order to safeguard water quality, a site-specific and <br /> resource protective criteria must form the basis for soil <br /> cleanup. The criteria then must be applied for all soil <br /> analytical data to determine the degree to which the site <br /> should be cleaned or remedial action is necessary. The <br /> RWQCB "Designated Level Methodology" for cleanup level <br /> determination, or it's equivalent, must be used to support <br /> this criteria for establishing remedial action goals for <br /> soil. Based on application of the cleanup criteria, <br /> supported by a qualitative site analysis, contaminant source <br /> areas can be appropriately characterized and defined for the <br /> proposed remedial actions to be applied and remedial action <br /> goals to be satisfied. As a result of applying the above <br /> criteria, estimated volumes of contaminated soil requiring <br /> remediation may change resulting in the need for <br /> re-evaluation of alternatives and thus requiring a <br /> major modification to the FS. <br /> 2 . Section 9 of the FS discusses conclusions and <br /> recommendations for soil remedial actions to be taken for <br /> the site. The first paragraph concludes human health risks <br /> from current exposure to the site, as determined in the risk <br /> FA.bdi <br /> FA25W.125\1 <br /> A <br /> 1.M* <br /> Pnn@d On ReCydpE Paper <br />