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California Regional Water Quality Control Board <br /> Central Valley Region <br /> Steven T.Butler, Chair _ GravDaN is <br /> Winston H.Hickoz ', -Governor <br /> Secretaryfor Sacramento Main Office <br /> Environmental Internet Address: hitp://w .sw cb.ca.gov/nvgcb5 C �, <br /> Protection 3443 Routier Road,Suite A,Sacramento,California 95827-3003 <br /> Phone(916)255-3000•FAX(916)255-3015rr <br /> N <br /> 22 June 2000 <br /> Mr. Mark Adams <br /> Lincoln Center Environmental Remediation Trust <br /> Point Environmental <br /> 137 Park Place <br /> Richmond, California 94801 <br /> DRAFT FEASIBILITY STUDY, LINCOLN VILLAGE CENTER, STOCKTON, SANJOAQUIN <br /> COUNTY <br /> I have reviewed the 5 May 2000 Draft Feasibility Study, Lincoln Center, Stockton, California (Draft FS) <br /> submitted by LFR Levine Fricke (LFR) for the Lincoln Center Environmental Remediation Trust <br /> (Lincoln Trust). The proposed remediation method, groundwater source reduction with an oxidant <br /> (ozone sparging), continued operation of the soil vapor extraction system (SVES), and expansion of the <br /> groundwater extraction and treatment system, is acceptable. Prior to system design and implementation, <br /> Lincoln Trust needs to conduct several pilot studies, including an ozone sparging treatability study and a <br /> B-Zone aquifer groundwater extraction test. I have the following comments on the Draft FS. <br /> GENERAL COMMENTS <br /> 1. Based on the Fourth Edition of the Water Quality Control Plan for the Sacramento River and San <br /> Joaquin River Basins (Basin Plan), groundwater cleanup goals range between background and the <br /> lowest water quality objective, not the maximum contaminant level (MCL). MCLs, one of several <br /> water quality objectives used to establish groundwater cleanup levels in this region, are drinking <br /> water standards adopted by the California Department of Health Services (DHS) and the <br /> U.S. Environmental Protection Agency (U.S. EPA). MCLS are not necessarily fully protective of <br /> human health. For example, at this site, the groundwater cleanup goal for PCE is 0.7 µ9/1, the U.S. <br /> EPA Suggested No-Adverse-Response Level (SNARL), not the MCL of 5 µg/l. Groundwater <br /> cleanup goals are shown in attached Table 1. <br /> 2. The Basin Plan states in part: <br /> "For soils which threaten the quality of water resources, soil cleanup levels should be equal to background <br /> concentrations of the individual leachable/mobile constituents,unless background levels are technologically or <br /> economically infeasible to achieve. Where background levels are infeasible to achieve, soil cleanup levels are <br /> established to ensure that remaining leachable/mobile constituents of concern will not threaten to cause ground water <br /> to exceed applicable ground water cleanup levels, and that remaining constituents do not pose significant risks to <br /> health or the environment. The Regional Water Board will consider water quality,health, and environmental risk <br /> assessment methods, as long as such methods are based on site-specific field data, are technically sound,and <br /> promote attainment of all of the above principles." <br /> California Environmental Protection Agency <br /> 0a Recycled Paper <br />