SITE INFORMATION AND CORRESPONDENCE

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FROM : D.M.STAUDENRAUS PHONE NO. : 415 788 6099 JUN. 25 1997 02,21PM P2 %"we DOLORES M. STAUDIENRAUS MONTGOMERY WASHINGTON TWR SUITE 2305 611 WASHINGTON STREET SAN FRANCISCO, CAUroRNIA 94111 PWOWE (4141768*6096 24 June 1997 Michael Infurna pHS/EuD - San Joaquin County P.O. Box 388 StacXton, CA 95201 RE. Remediation Project: 305 S. Hutchins, Lodi Dear Mike; Tlyt reviewed the copy of Mr. Moser's June 17th letter that you provided me and wish to cornent asfollows. It should be noted the letter presses for Site closure in advance of an immanent court imposed deadline. To assure this Texaco agrees to terms that include a plan for well maintanence and monitorinx- h It seems implicit it ext of that letter, as well as the terms, that Texaco's responsibilities are limited to accommodating other parties in their efforts to address a problem which, Texaco asserts, arise off site. TexavO-s responsibil- ities are constrained by time and unaffected by eventualities. The underlying assumption of the agreement must,then, be that there is concen- sus by all parties of interest that the Site itself has not contributed to the problem for which tbQ wells are to be retained. That assumption can't be re- conciled with the DISC letter of 2128/97 which states: "The Site has been deter- mined as a source for the I,2-DCA and other VOC's detected in soils and ground- water beneath the Site by DTSC." Further, the following statement taken from Mr. Moser's letter of 1/10/97 to the SWRCS misrepresents the position of the TRC in this regard. "The TING analyzed this issue at length and concluded that the 1,2-DCA in the groundwater beneath the Site is associated with degradation of PCE and TCE in the regional Lodi solvent plume, a plume which originates upgradient of the Site and which is shown on DISC maps to have 'reached the Site." The position of the TRC. as represented in the County's letter of 12/13/96 to S'WRCS is as follows: ..The only constit- uent the CVRVQCS is concerned with is 1,2-DCA. The TRC discussed the existence and levels of 1,2-]DCA in the groundwater extensively and concluded the 1.2-DCA is associated with the degradation of PCE and TCE as well as a past additive to gasoline.*# "Even if I,Z-DCA Is found in the soil at the Site, the source of the 1,2-DCA in the rroundwater may be the breakdown of the PCE and TCE." It would appear Mr. Moser seeks to establish Texaco as an innocent party in these matters simply by agreeing to terms that inherently infer this to be so. If I am in error on this , please advise me Request the Opportunity to review a draft of the closure letter prior to issue. Sincerely, ok�__