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DAMES & MQORE. <br /> 8901 FOLSOM;BOULEVARD, SUITE 200, SACRAMENTO, CALIFORNIA 95826 <br /> (916) 387-8800 FAX! (916)387-0802 <br /> April 14; 1995 <br /> Public Health Service-Environmental Health.Division <br /> San Jbaquin.County APR 17 1995 <br /> -445 N. San Joaquin Street <br /> `P.4. Box 388 ENVIRONMENTAL HEALTH <br /> Stockton, CA , 95201-0388 PERMIT/SERVICES <br /> .Attention: Steve'Sasson. <br /> 1 � <br /> Sept via fucirniiie and reg iar mail; <br /> Re: Former AFDC Facility. 1 <br /> I 2801 West.Lane <br /> Stockton, California <br /> II - <br /> j Dear Steve: <br /> This letter confirms our conversation'on Wednesday, April 12, 1995. As we discussed., . <br /> Dames &Moore has received,and reviewed your March.l; 1995 letter and have again reviewed the <br /> technical documents relating to the remediation of this site.„We also have.discussed your.letter with <br /> American,Forest.Products Company (AFDC) and Kukland & Ellis.,. AFPC's legal counsel. <br /> As we discussed, AFPC and'°Dairies.& Moore do not agree that a 100-ppm cleanup standard <br /> is the appropriate soil standard-for this 5ite.- We base our position in this regard on the nature of the <br /> materials involved, our past groundwater quality,analyses, and,the results of the fate-and-transport <br /> modeling that was conducted last summer (Dames&Moore, August 1994). In particular, we believe <br /> G that the PHSIEHD has not given adequate consideration to the low leachability of the source material <br /> at this site, and is'basing.its,position on3historical-groundwater data that are not representative of <br /> current or reasonably anticipated conditions. <br /> At the present.time, we believe that in'situ remedies.could not reasonably be expected to <br /> attain a 100-ppm'standard. Although implementation of an excavation remedy could attain such a <br /> standard-, the cost .associated with such a remedy (estimated by Dames & Moore to exceed <br /> I <br /> $1,900;000)is simply.not justified by site conditions. which-do not.present, in our view, a significant <br /> wY <br /> risk ofgroundwater contamination (see ,Technical Evaluation,: Dames.&;Moore, November 1994). <br /> SAC146.12 <br /> OFFICES WORLDWIDE <br />