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• <br /> California Regional Water Quality Control Board <br /> 0Central Valley Region } y <br /> Robert Schneider,Chair <br /> Winston A.FIickox Gray Davis <br /> Secretaryfar Sacramento Main Office Governor <br /> Environmental Internet Address: http://w .swrcb.ca.gov/rwgcb5 <br /> Protection 3443 Routier Road,Suite A,Sacramento,California 95827-3003 <br /> Phone(916)255-3000•FAX(916)255-3015 <br /> "1 <br /> 25 April 2001 <br /> Mr. Ken Price <br /> Glenn Springs Holdings, Inc. <br /> 2480 Fortune Drive, Suite 300 <br /> Lexington, KY 40509 <br /> REVISED FEASIBILITY STUD YFOR SOIL REMEDL4TION, OXYCHEMISIMPL 0 T <br /> FACILITY, STOCKTON, SAN JOAQUIN COUNTY <br /> We have reviewed the 13 July 1999 Revised Feasibility Study for Soil Remediation (feasibility <br /> study) for the former Occidental Chemical Co./Simplot Co. (OxyChem/Simplot) facility at 1904 <br /> W. Charter Way in Stockton prepared by Geomatrix Consultants, Inc. The feasibility study <br /> proposes a remediation method that requires OxyChem/Simplot to have control of the property <br /> for an extended time that, as discussed below,was not possible until this summer. We have the <br /> following comments on the feasibility study: <br /> 1. The feasibility study concludes that the most feasible soil remediation alternatives for the site <br /> are excavation with low temperature thermal desorption and phytoremediation. Excavation <br /> and treatment with low temperature thermal desorption and phytoremediation of nitrogen <br /> compounds in soil are proven remedial alternatives for on-site chemicals of concern and are <br /> acceptable. Phytoremediation of pesticide concentrations remaining in the soil after <br /> excavation is not a proven technology. However, remaining pesticide concentrations are such <br /> that the trees should uptake sufficient chemicals to achieve cleanup. Additionally, <br /> phytoremediation will have a low impact on the surrounding community. We accept <br /> phytoremediation of soil on the conditions that: <br /> a. OxyChem/Simplot realizes we consider this an unproven soil remediation technology for <br /> the range of chemicals at the site; <br /> b. As stated in the feasibility study, the phytoremediation will be conducted as a two-year <br /> demonstration to evaluate the efficacy for the range of chemicals; and <br /> c. Adequate site access is secured(see comment 2 below). <br /> 2. The selected remedial alternatives will require intensive use of the property for an extended <br /> period of time (i.e., at least two years for the demonstration project and greater than five years <br /> if the alternative is effective). Other remedial alternatives for soil will also require full, <br /> California Environmental Protection Agency <br /> 0 Recycled Paper <br /> The energy challenge facing California is real. Every Californian needs to take immediate action to reduce energy consumption. For a list of - <br /> simple ways you can reduce demand and cut your energy costs,see our Web-site at hup://www.swrcb.ca.gov/mgcb5 <br />