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V <br />Peter M. RooneN, <br />Secretaryfor <br />Environmental <br />Protection <br />California regional Water QualitrControl Board <br />13 October 1998 <br />Mr. Werner Sicvol <br />BP Oil Company <br />200 Public Square 7-I <br />Cleveland, Ohio 44114-2375 <br />Central Valley Region <br />Sacramento Main Office <br />Internet Address: htip://\\•ww.s",rcb.ca.gov/—rwgcb5/home.html <br />3443 Routier Road, Suite A, Sacramento, California 95827-3003 <br />Phone (916) 255-3000 • FAX (916) 255-3015 <br />a�. <br />Ed J. Schnabel <br />Chair <br />COMMENTS ON THE REMEDIAL ACTION WORK PLAN, BP OIL COMPANY/APPLIED <br />AEROSPACE STRUCTURES CORPORATION, STOCKTON, SAN JOAQUIN COUNTY <br />I have reviewed the 27 August 1998 Remedial Action Work Plan for Former Hazardous <br />Materials/Waste Storage Facility for the BP Oil Company/Applied Aerospace Structures Corporation <br />site in Stockton. The work plan presents alternatives to remediate soil and groundwater at the site. Soil <br />vapor extraction (SVE) is the selected alternative to clean up volatile organic compound (VOC) <br />contamination in soil. Limited groundwater pumping and treatment (P&T) and/or natural attenuation is <br />being considered to treat VOC-contaminated groundwater. My comments on the work plan are <br />presented below. <br />General Comments on SVE and Groundwater P&T <br />The work plan proposes to operate the SVE and P&T systems in two phases. Phase I will focus on <br />removing the higher concentrations of VOCs from the source zone and will be operated until greater <br />than 90% reduction from the initial VOC concentrations (at start up) is achieved. Phase II would start <br />after a one-month (SVE) and three-month (P&T) rest periods from the cessation of Phase I operations to <br />allow the VOC contaminants to desorb from the soil particles. <br />BP Oil should remediate VOCs in the vadose and saturated zones to the extent technologically or <br />economically feasible. Cleanup will be achieved when it is demonstrated that: <br />The remaining vadose zone VOC contaminants no longer cause concentrations in the leachate to <br />exceed the aquifer background levels, based on soil confirmation sampling and an interpretation of <br />soil gas data using an appropriate vadose zone model; and <br />2. Background groundwater quality has been reached (since the constituents of concern are not <br />naturally their background concentration is zero); and <br />3. VOCs have been removed to the extent technologically or economically feasible. <br />California Environmental Protection Agency <br />7 Recycled Paper <br />