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COMMENTS <br /> RI/FS Work Plan Review <br /> Marley Cooling Tower Company <br /> Stockton, California <br /> The following comments pertain to the proposal (Work Plan) <br /> titled "Current Status and Proposed Work Plan for Mitigation <br /> Activities" which was submitted by the Marley Cooling Tower <br /> Company on June 19 , 1986. The comments are presented under two <br /> subheadings: Remedial Investigation Activities and Feasibility <br /> Study Activities. <br /> Remedial Investiqation Activities: <br /> 1 . Existing data indicates that migration of chromium from soil <br /> into the ground water is occurring. It is not clear whether <br /> enough contaminated soil data has been gathered to develop <br /> and evaluate potential remedial action alternatives involving <br /> soil excavation. MCTC should detail in the Work Plan whether <br /> the contaminated soil has been characterized sufficiently to <br /> develop and evaluate alternatives involving contaminated soil <br /> removal or describe the data still necessary and how it will <br /> be developed. <br /> 2. The potential for airborne transport of contaminants off-site <br /> has not been addressed. Assessing the significance of this <br /> potential environmental media transfer may require site <br /> characterization activities. MCTC should detail in the Work <br /> Plan whether this pathway has been characterized or describe <br /> the data still necessary and how it will be obtained. <br /> 3. The proposed site assessment activities for further character- <br /> izing the ground water contaminant plume appear adequate. <br /> Additional ground water characterization data may be necessary <br /> to properly design and evaluate remedial action alternatives. <br /> For example, the location and number of ground water extraction <br /> wells necessary to contain the contaminant plume and clean up <br /> the aquifer may require the performance of pump tests. <br /> 4. The sampling plan for characterizing soils in the drainage <br /> ditches surrounding the South Yard appears adequate for <br /> determining the extent of surface migration of contaminants <br /> in soil. The resultant data from these activities and the <br /> surface water run-off data should be sufficient to begin <br /> evaluating controls and remedial responses to surface <br /> contaminant migration if warranted. <br /> It is unclear whether locations other than the retort area in <br /> the North Yard could contribute to contaminant migration into <br />