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DEER <br /> LEVINE• FRICKE <br /> May 30, 2001 6752.00-017 <br /> via U.S. Mail <br /> Mark A. Adams, R.G., Trustee <br /> Lincoln Center Environmental Remediation Trust <br /> 137 Park Place <br /> Richmond, California 94801 <br /> Subject: Response to Lincoln Properties Ltd. Review of the Proposed Phase III Interim <br /> Remedial Action(IRA) Detailed Plan, Lincoln Center, Stockton, California <br /> Dear Mr. Adams: <br /> LFR Levine-Fricke (LFR) has reviewed the comments prepared by Farr Associates (FA) on behalf <br /> of Lincoln Properties, Ltd. (LPL) to LFR's Phase III Interim Remedial Action (IRA) detailed plan <br /> for the Lincoln Center site in Stockton, California ("the Site"). The Phase III IRA detailed plan <br /> was submitted to LPL on April 2, 2001. LPL's comments were presented in a letter to Mr. Mark <br /> Adams, Trustee of the Lincoln Center Environmental Remediation Trust ("the Trust"), dated May <br /> 8, 2001. <br /> This letter presents LFR's responses to LPL's comments, in the order presented in FA's letter. <br /> Each comment is reproduced here, followed by LFR's response. This letter is presented as an <br /> addendum to the Phase III IRA detailed plan. Changes in the text to acknowledge LPL's comments <br /> are presented here. <br /> GENERAL COMMENTS <br /> COMMENT 1 <br /> The proposed Phase III IRA objective stated in Section 1.2 and 3.3 is to"reduce concentrations of PCE in ..... groundwater." <br /> LPL believes that the primary objective for the proposed Phase III IRA should instead be to`limit the downgradient migration <br /> of site hazardous substances in groundwater to the extent practicable."or something similar. Groundwater extraction and <br /> treatment systems designed for leading edge plume control or capture at dense nonaqueous phase liquid(DNAPL)release sites <br /> typically contribute little to the removal of contaminant mass and the reduction of contaminant concentrations,and the current <br /> objective stated in the Phase III IRA Plan misleadingly implies that significant reductions in contaminant concentrations will be <br /> achieved by the proposed Phase III IRA. <br /> 1900 Powell Street, 12th Floor, Emeryville, California 94608-1827 • (510) 652-4500 • fax (510) 652-2246 • www.ifr.com <br /> Offices Worldwide <br />