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Pacific Gas and Electric eompany One Caldorma Stree', Room F 1601 • Victor C Furtado.Ph.D. <br /> San Francisco,CA Manager <br /> ` 415 972.7746 Enwronmer.;al Services <br /> f telex 972 6888 <br /> December 3, 1991 P O Box 7640 <br /> San Francisco.CA 94120 <br /> Mr. Val F. Siebal <br /> California Environmental Protection Agency �, L klaw <br /> Department of Toxic Substances Control DEC 9 "^ 9 <br /> 10151 Croydon Way <br /> Sacramento, CA 95827 ENVIPONMENTAL Nr --, H <br /> Attention: Mr. Fernando Amador <br /> Dear Mr. Siebal : <br /> Re: Docket #HSA 90/91-08 - Stockton Mamrfactured Gas Plant Site <br /> Subject: Interim Remedial Measure Work Plan <br /> I am writing in response to your November 25, 1991, letter regarding the <br /> document, "PG&E Stockton Former MGP Site Interim Remedial Measure Work <br /> Plan." That letter identifies two issues which are discussed further <br /> below. <br /> Schedule. PG&E requests a thirty (30) day extension of the December 15 <br /> due date to January 15, 1992. The original schedule assumed DTSC <br /> approval of the IRM Work Plan on September 15. Contingent approval was <br /> received by PG&E in your October 11 letter, but we understood that to <br /> mean that work should start after the contingencies were removed. DTSC <br /> clarified its position on November 24, and PG&E began work immediately. <br /> We have begun implementation of the Work Plan Tasks 1 and 2; soil <br /> sampling activities will be performed on December 4. We have worked <br /> with our contractor on strategies to expedite the schedule as much as <br /> possible; however, the December 15 due date cannot be met. By <br /> expediting our laboratory schedule, we believe we can meet a January 15 <br /> deadline. <br /> Scope of Work. PG&E agrees that the purpose of the IRM is to eliminate <br /> potential direLt human exposure to res;dues at the site. However, it <br /> has not yet been established that any gas plant residues or hazardous <br /> substances are present in the soils on the Hazelton Avenue strip. No <br /> chemical analyses have been performed to our knowledge on these soils. <br /> The property is not currently, nor has it ever been, owned by PG&E. <br /> Further, this property was not a part of the manufactured gas plant; <br /> rather, it was formerly used as a road base and as a railroad spur. <br /> Therefore, PG&E considers chemical analyses of these soils as a <br /> necessary first step prior to proposing any specific remedial action. <br /> Once the nature and extent of such chemicals, if any, are known, a <br /> reasonable remedial action can be identified. This is the approach we <br /> have outlined in the IRM Work Plan. <br />