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BL F R ENVIRONMENTAL MANAGEMENT&CONSULTING ENGINEERING <br /> July 11, 2006 001-06750-05-323 <br /> Mr. Mark Adams <br /> Lincoln Center Environmental Remediation Trust <br /> 137 Park Place <br /> Richmond, California 94801 <br /> Subject: Response to Farr Associates Letter Dated March 30, 2006 Regarding Feasibility Study <br /> for the Lincoln Center Site, Stockton, California <br /> Dear Mr. Adams: <br /> This letter has been prepared by LFR Inc. (LFR), at the request of the Lincoln Center <br /> Environmental Remediation Trust ("the Trust") to provide responses to the above-referenced letter <br /> from Farr Associates (FA) written on behalf of Lincoln Center Properties Ltd. This letter presents <br /> LFR's responses to FA's comments in the order presented in FA's letter. Each comment is <br /> reproduced here, followed by LFR's response. Overall, LFR finds that the data collected to date <br /> continue to validate the Site Conceptual Model (SCM) as previously presented in the Remedial <br /> Investigation Report and prior documents, and that many of FA's comments conflict with the <br /> SCM. <br /> FA Comment 1: <br /> LCERT has recognized the persistence of VOCs in the "Historical Source Area," located in the <br /> western portion of Lincoln Center near Benjamin Holt Drive, and has conducted several pilot <br /> studies and special investigations to support the selection and design of remedial actions for this <br /> area. However, high concentrations of VOCs (principally tetrachloroethene - PCE) in groundwater <br /> east of the "Historical Source Area" (the Eastern Hot Spot) are not receiving any special attention, <br /> even though the PCE concentrations observed in this area are similar to those observed in the <br /> "Historical Source Area." <br /> The existing site data are sufficient to conclude that persistently high PCE concentrations have been <br /> observed in the Eastern Hot Spot. Selected PCE concentrations observed in groundwater east of the <br /> "Historical Source Area" are as follows: <br /> 510.652.4500 m <br /> 510.652.2246 f <br /> 1900 Powell Street, 12th Floor www.Ifr.com <br /> Emeryville, California 94608-1814 <br /> Offices Nationwide <br />