SITE INFORMATION AND CORRESPONDENCE

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Mr.Michael Harper January 10, 1997 Page 4 If � r deliberation, whichlastedEthe entire day, the TRC concluded that the site should be closed with no further.action required. In response,the CVRWQCB issued a nonconcurrence letter slated Nove illw 26, 1996 On December;13; 1996,;PHS-EHD requested,tha€you:rescIve this dispute between rt;and the C- d B. Ifi InrliviMIt It M69URE OF THE SITE IS APPROPRIATE It is apparent f turn the history recited above,Viand the information.provided to you.by the PHS-EHD; that extensive investigation and remediation has occurred at this site. Also,the risks posed to human health and the environment'by the residual contamination are extremely:low els pointed out in PHS-EHD's letter to you,the CVRW. Q.C. Rnonconcurrence letter does not consider th$primary constituents of gasoline'to require any further investigation or remediation at the site. Rather,the CVRWQCB is concerned about the: occurrence of 1,Z DCA in the groundwater, and whether theme is a possibility that the source ofthis I, DCA is.this:site,rather than an off-site source. The TRC analyzed this precise issue at length; and concluded that the 1,2 DCA in the groundwater beneath the site is associated with the degradation of PCE and TCE in the regional Lodi solvent plume,a plume which originatedupgradient of the site, and which is shown on Department of Toxic Substances Control maps to have reached the site. , i For this reason, and the additional reasons articulated by the PHS-EHD, 3 further investigation and remediation of the 1,2 DCA are not warranted, and will not be cast effective. ' a 1� For the reasons explained above,Texaco respectfully requests that you resolve; the dispute between the PHS-EHD and the CVRWQ+CB by determining in accordance with ' the TRC that further investigation and remediation at this site is not warranted, and that immediate closure of the site is appropriate. Very tpily yours, F David E. oser i C k a l�