Laserfiche WebLink
04/14/95 17:00 FAA 91.6 :9s/ vauz <br /> 4 <br /> DAMES & MQ RE <br /> Hfiol POISON BOULEVARD,MTV-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 Joaquin County <br /> 445 N. San Joaquin Street <br /> P.O. Box 388 <br /> Stockton, CA 95241.-03118 <br /> Attention Steve Sasson <br /> Sent via facimflie and regular mail <br /> Re: Fourier AFPC Facility <br /> 2881 West Lane <br /> Stockton California <br /> 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 1, 1995 letter and have again reviewed the <br /> icchrucal documents relating to the remediation of this site. We also have discussed your letter with <br /> American Forest Products Company (AFPC) and. Kirkland& Ellis, AFDC's legal counsel. <br /> As we discussed, AFPC and Dames &Moore do not agree that a 100-ppm cleanup standard <br /> is the appropriate soil standard for this site. 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 /> that 6e PHSfEHD has not given adequate consideration to the low leachability of the source material <br /> at this site, and is basing its position on historical 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 flames & Mom to exceed <br /> $1,900,000) is simply not justified by site conditions, which do not present, in our view, a significant <br /> risk of groundwater contamination (see Technical Evaluation, Dames & Moore, November 1994). <br /> SAC[46.12 <br /> OFRCFS WORLDW CE <br />