SITE INFORMATION AND CORRESPONDENCE

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Mr. Andre Arnold Department of General Services Deuel Vocational Institution - 2 - 24 January 2003 Remediation Project, Department Of Corrections, Deuel Vocational Institution, 23500 Kasson Road Tracy, San Joaquin County, California (Assessment). Board Staff submitted comments to the Assessment and requested an addendum. The addendum, 4 October 2002,Appendix D, Sensitivity Analyses For VLEACHModeling, adequately addressed Board staff comments to the Assessment. Our comments on the Report are presented below. General Comments 1. We concur that no further action(NFA)is required at this time for remediation of site soils at the DVI Fire Pit. Nothing in this determination shall constitute or be construed as a satisfaction or release from liability for any conditions or claims arising as a result of past, current, or future operations at this location. Nothing in this determination is intended or shall be construed to limit the rights of any parties with respect to claims arising out of or relating to deposit or disposal at any other location of substances removed from the site. If existing, additional, or previously unidentified chemical constituents at the site cause or threaten to cause pollution or nuisance or are found to pose a threat to public health or water quality,then 1) nothing in this determination is intended or shall be construed to limit or preclude the Board or any other agency from taking any further enforcement action, and 2) this letter does not relieve DVI of any responsibilities mandated under the California Health and Safety Code and the California Water Code. Changes in land use may require further assessment and mitigation. 2. We concur with the recommendation for groundwater extraction from MW-5. Because, a WDR was adopted for the site,remedial alternatives evaluated and presented in the report were primarily limited to pump-and-treat methods. The Department of General Services (DGS)plans to use the WDR as the basis of compiling a bid request. A Workplan for implementation of the chosen remedial method that includes detailed schematics of the treatment system design, and procedures for conveying treated groundwater to, and distributing treated groundwater within the spray field is required. The Workplan should include the basis used to determine the proposed extraction rate of 20 gallons per minute (gpm) and calculated treatment times and volumes. 3. If groundwater cleanup goals are not attained within eight quarters of operation (two years) of the remedial system, DVI must submit a system performance evaluation. The evaluation will either present optimization recommendations for the existing system or alternate remedial alternatives for attaining cleanup goals. Specific Comments 1. DVI must determine whether MW-15, currently buried by soil, is intact. If the well has been damaged it must be restored prior to the next sampling event in order to permit ground water monitoring activities.