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o1a Department of Toxic Substances Control ib <br /> Linda S.Adams Maureen F. Gorsen, Director <br /> 8800 Cal Center Drive Arnold Sch gger <br /> Secretary for E <br /> (, � Governor <br /> Environmental Protection Sacramento, California 95T <br /> vAPril 18 2008 h.��`J <br /> 2 2008 <br /> ENV1�,�'IiTISFRVICES H <br /> Ms. Melitta Rorty, P.G. pER <br /> Environmental Remediation <br /> Pacific Gas and Electric Company <br /> 77 Beale Street, Mail Code B24A <br /> San Francisco, California 94105 <br /> DRAFT REMEDIAL INVESTIGATION WORK PLAN, PACIFIC GAS AND ELECTRIC, <br /> FORMER LODI MANUFACTURED GAS PLANT, LODI, CALIFORNIA <br /> Dear Ms. Rorty: <br /> The Department of Toxic Substances Control (DTSC) has reviewed the Draft Remedial <br /> Investigation Work Plan, Former Lodi Manufactured Gas Plant (Work Plan) dated <br /> March 4, 2008. This Work Plan was prepared by SECOR International Incorporated on <br /> behalf of the Pacific Gas and Electric Company (PG&E). DTSC's project manager, <br /> Geological Services Unit (GSU), and Human and Ecological Risk Division provide the <br /> comments below for your consideration. Please provide a response to each of the <br /> comments. <br /> COMMENTS <br /> GENERAL COMMENT <br /> 1) A review of 2006 sampling results shows polycyclic aromatic hydrocarbons (PAHs) <br /> at high levels at the Site property boundary especially to the northeast, south, southwest <br /> and due west. Due to the nature and operation of town gas plants PAH contamination likely <br /> continues off-Site in these directions. <br /> Recommendation: Remedial investigation cannot be considered complete until the full <br /> vertical and horizontal extent of contamination is determined. Environmental samples are <br /> needed off-Site in these directions. <br /> SPECIFIC COMMENTS <br /> 1) The Work Plan discussed two and possibly three inactive water production wells on <br /> the Site. These wells should be investigated and properly decommissioned to insure <br /> against the vertical spread of Site constituents. <br /> ® Printed on Recycled Paper <br />