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STATE OF CALIFORt—HEALTH AND WELFARE AGENCY GEORGE DEUKMEJIAN, Governor <br /> DEPARTMENT OF HEALTH SERVICES <br /> TOXIC SUBSTANCES CONTROL DIVISION "n.. <br /> NORTHERN CALIFORNIA SECTION <br /> 4250 POWER INN ROAD April 24 , 1987 �, <br /> I <br /> SACRAMENTO.CA 95826 <br /> 1916)739-3145 IlW�4" V <br /> Mr. James B. O'Connor MAY 10 F7 <br /> Group General Manager ENVIROMEN7AL HEALTH <br /> LIKA Corporation F <br /> 1443 Navy Drive ERMIT/SERVICES <br /> Stockton, CA 95206 <br /> Dear Mr. O'Connor: <br /> LIKA FIELD AVENUE ANNEX DRAFT REMEDIAL ACTION PLAN COMMENTS <br /> The Field Avenue Annex draft Remedial Action Plan (RAP) dated 25 <br /> March 1987 has been reviewed. This letter is written to provide <br /> you with the Department's comments on the RAP. These comments <br /> supplement comments from our Headquarters Technical Services <br /> staff hand delivered to your consultant on 9 April 1987 . A <br /> formal transmittal of these comments is made by Attachment 1. <br /> Please understand that we cannot yet approve your draft RAP. In <br /> particular, groundwater contamination must be better defined and <br /> groundwater extraction may be necessary. Because of these <br /> unresolved groundwater issues we strongly recommend that wells <br /> currently on site not be abandoned or removed. <br /> 1. The direction of groundwater flow is poorly defined. <br /> The horizontal and vertical extent of groundwater <br /> contamination is not adequately documented. <br /> Correlation of ship channel elevations and <br /> depths-to-groundwater in monitoring wells are needed at <br /> frequent intervals over tidal cycles (see HQ comment <br /> letter) to present a time-history of water elevations. <br /> Installation of wells screened at different depths is <br /> needed to analyze groundwater quality at various depths <br /> and determine if alsignificant vertical gradient <br /> exists. <br /> 2 . Some presentation of events surrounding the removal of <br /> the ductile iron sewer needs to be made. We understand <br /> that soil contamination occurred from the corroded <br /> iron pipe connecting the industrial sump to the city <br /> sewer. The corroded DI pipe was removed and backfilled <br /> after soil sampling and analysis. No presentation of <br /> sample data has been made. Neither has any information <br /> confirming the limited extent of pipe corrosion. No <br /> statements have been made describing when the PVC pipe <br /> was replaced with ductile iron. <br /> 3 . Cracks along the western edge of the wet-room wall <br /> exhibit a lack of concrete structural integrity. <br /> Further samples must be taken here to adequately <br />