SITE INFORMATION AND CORRESPONDENCE_2001-2005

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California. RegionantWate tral ValyQ gality Control Board Rn Robert Schneider,Chair Gray Davis Governor Winston H.Hickox Sacramento Main Office Secretaryfor Environmental Internet Address: http://www.swrcb.ca.gov/mgcb5 Protection 3443 RPhtone Road,6)255 3000 Sacramento, FAX(91'fornia 6)255-3052 7 3003 February 13, 2003 �E Mr. Mark Adams ��T� Lincoln Center Environmental Remediation Trust EN FEB 18 2003 Point Environmental 137 Park Place PEQQIT SFR�� 5 ry Richmond, CA 94801 REVISED DRAFT FEASIBILITY STUD Y, LINCOLN VILLAGE CENTER, STOCKTON' SAN JOAQUIN COUNTY We have reviewed the Lincoln Center Environmental Remediation ed b LFR LeviCERT) submittal LFR) anentitled d "Revised Draft Feasibility Study, Lincoln Center" (FS)prepY August 5, 2002. Our comments are provided below. Background Lincoln Center is a commercial property located in Stockton where dry cleaning facilities historically disposed of dry cleaning fluids into the sanitary sewer that subsequently leaked,resulting in the contamination of the underlying soil, soil vapor and groundwater. The LCERT was created by the Federal Court as part of a settlement of a lawsuit associated with the contamination. To date,the remedial investigation has been conducted, the health risk assessment has been completed, and two removal actions have been conducted at the site. The removal actions consisted of the installation of a groundwater extraction and treatment system and the installation of a soil vapor extraction system. Comments on the Draft Feasibility Study 1. Section 2.2, entitled"Applicable or Relevant and Appropriate Requirements", describes the nature of State Requirements, or Applicable or Relevant and Appropriate Requirements ("ARARs") and refers to Appendix A where potential ARARs are set forth in detail. We disagree with the Appendix A list of ARARS as they are incomplete. Attached are two tables developed by the State Water Resources Control Board, Office of Legal Counsel, that set forth potential State ARARs related to water quality. One table lists potential ARARs for groundwater remediation and the other table lists potential ARARs for soil cleanups. Appendix A of the FS should be revised to reflect the ARARs as listed in the attached tables 2. Section 2.3, entitled"Remedial Action Objectives for Soil" states: California Environmental Protection Agency 01 Recycled Paper The energy challenge facing California is real. Every Californian needs to take immediate action to reduce energy consumption. For a list of simple ways you can reduce demand and cut your energy costs,see our Web-site at http://www.swrcb.ca.gov/rwgcb5