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• 0ECaVIED <br /> OURENVIRONMENTAL MANAGEMENT&CONSULTING ENGINEERING AUG 2 4 2007 <br /> ENVIRONMENT HEALTH <br /> Via email and Hard Copy PERMIT/SERVICES <br /> August 16, 2007 001.06750.07 <br /> Mr. Mark A. Adams, P.G. Trustee <br /> Lincoln Center Environmental Remediation Trust <br /> 137 Park Place <br /> Richmond, California 94801 <br /> Subject: Response to LPL's June 14, 2007 Comments on LFR's Draft Proposed Phase V <br /> IRA Detailed Plan for the Bank of Stockton Area Adjacent to Lincoln Center, <br /> Stockton, California <br /> Dear Mr. Adams: <br /> This letter is in response to LPL's June 14, 2007 comments on LFR's Draft Proposed Phase V <br /> IRA Detailed Plan for the Bank of Stockton Area adjacent to Lincoln Center, Stockton, California. <br /> The implementation of the Phase V Plan was also discussed in a June 13, 2007 conference call <br /> attended by Mark Adams of Lincoln Center Remediation Trust, Marie McCrink of the Regional <br /> Water Quality Control Board (RWQCB), John Farr of Farr Associates, David Sadoff of AIG, and <br /> Lucas Goldstein of LFR. For ease in review, LPL's comments are numbered and italicized with <br /> responses following each numbered comment. <br /> Comment 1: <br /> Contingency Plan for B-Zone Implementation <br /> The contingency plan for ERD implementation in the B-zone, briefly discussed in the last <br /> paragraph on page 3, Section 1.2, needs to be discussed more fully in the Detailed Plan. A <br /> presentation of conceptual plans for implementing ERD in the B-Zone is required in the Detailed <br /> Plan, similar to the conceptual plans already presented for A-zone implementation. The <br /> preliminary schedule for the Phase V IRA, presented on Figure 9, should also contain the <br /> preparation and distribution of a report that thoroughly evaluates the need for B-zone <br /> implementation of ERD no later than January 15, 2008. B-Zone implementation of ERD should not <br /> be delayed simply because `favorable geochemical conditions"exist for natural reductive <br /> dechlorination in the B-zone. Instead, LFR and LCERT must demonstrate that an acceptable rate <br /> of decrease in the concentrations of Hazardous Substances (HS) is occurring due to natural <br /> reductive dechlorination. In the context of the B-zone evaluation report, an "acceptable rate of <br /> decrease in HS concentrations"should be defined to mean that acceptable groundwater cleanup <br /> levels can be achieved without enhancement through active ERD implementation within a <br /> reasonable time frame. <br /> It is our professional opinion that the relatively high HS concentrations observed in the B-zone in <br /> the area between Pacific Avenue and Inglewood Drive, coupled with the relatively rapid HS <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 />