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MW <br /> CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD <br /> CENTRAL VALLEY REGION FjajVjMUPJ°'L� (rC�p�l ��� I' <br /> 3443 Routier Road, Suite A �V A Th <br /> Sacramento, CA 95827-3099 ao%+IT '`li\9�1L <br /> F,40NE: (916) 255-3000 l l L <br /> FAX: (916) 255-3015 4? Pdol' 2? Pp1 2: 40 <br /> 18 November 1993 <br /> Mr. Roy Thun, Chair <br /> Stockton Terminals Technical Committee <br /> C/O ARCO Products Company <br /> P.O. Box 2570 <br /> Los Angeles, CA 90051-0570 <br /> COMMENTS ON THE INTERIM REMEDIAL ACTION PLAN, STOCKTON TERMINALS <br /> TECHNICAL COMMITTEE, SAN JOAQUIN COUNTY <br /> We have reviewed EMCON Associcates' October 1993 Interim Remedial Action Plan for the fuel <br /> terminals of the Stockton Terminals Technical Committee (STTC) at the Port of Stockton. Board <br /> staff comments are presented below. <br /> General Comments <br /> The work plan recommends evaluating the efficacy of passive free product recovery methods and <br /> treatment of dissolved petroleum hydrocarbons using enhanced biodegradation. The work plan <br /> states further that data from the Phase Il assessment work will be used to evaluate the final design <br /> and implementation of the proposed remedial measures. <br /> Except for the enhanced biodegradation, the work plan is recommending interim measures that were <br /> proposed in EMCON's April 1992 Feasibility Stada;f©r Floating Product Rennoval Ince;im <br /> Measures, and should already be implemented. Since remediation is going to be conducted in <br /> phases, adequate data are already available, at least in Zone A, to allow evaluation of long-term <br /> remedial alternatives such as soil vapor and ground water extraction. The additional data which will <br /> be obtained during the Phase II investigation can be used to refine the evaluation and selection of <br /> remedial alternatives. <br /> Specific Comments <br /> 1. The work plan states the lateral and vertical extent of contamination has not been defined, <br /> and the impacts of the Zone A actions on contaminant migration into the lower zone have not <br /> been evaluated. <br />