SITE INFORMATION AND CORRESPONDENCE_FILE 1

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\.d Ultrarriar/former Beaoon-#419 page 2 2350 Waterloo Rd., Stockton. Gds J As stated in recent correspondence regarding other ULTRAMAR sites with PAR/CAP submittals in San Joaquin County, it is the purpose of the `feasibility' portion of the CAP to evaluate the cost-effectiveness, viability, and actual feasibility of each alternative. Site-specific data is required for each alternative evaluated in order to successfully conclude that a remedial alternative is feasible. As with the other PAR/CAP submittal, this report did not include a full evaluation, including costs and time allotment estimates for each of the remedial alternatives listed. With `over-excavation' as an example, a discussion should have included the method of soil removal, the calculated amount of soil to be removed, storage and disposition of the soil, a time requirement for the start-to-finish process, cost estimates, and a discussion of the `down-time' for thee gas station located Vthis site. SVE was the only alternative discussed beyond the general principles involved for each alternative, and still did not include costs or duration. EHD questioned the validity of including `over-excavation' as a remedial alternative in a recent letter to you regarding another former ULTRAMAR site in San Joaquin County (former Beacon #419, EHD April 23, 2002). Over- excavation at an active gas service station owned by others and at a site with contamination deep in the saturated zone is also not relevant for this site. As with previous EHD comments concerning `over-excavation' as a remedial option, listing `passive remediation' for this site seems just as inconsistent with the intent of a CAP for this site as it was for your other ULTRAMAR site. The CAP portion of this report is generic and incomplete. With only one alternative actually field-tested and evaluated, you have not complied with the minimum requirements of the feasibility study portion of the CAP and further testing, evaluation, and comparison is required. Without costs, time schedules, or any site-specific discussion included in the CAP, EHD was unable to ascertain a true picture of the cost-effectiveness or feasibility of any of the comparative remedial methods included in this report. The CAP portion of this report is unacceptable and not approved. Please submit a revised CAP that includes field tests, evaluations, and comparison of at least two viable and feasible, potentially cost-effective, and site- specific remedial alternatives for returning the contaminated soil and groundwater to pre-release conditions. If further field work is required to collect data to support conclusions and provide information for time and costs, then a work plan should be submitted in a timely manner.