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OURENVIRONMENTAL MANAGEMENT&CONSULTING ENGINEERING <br /> July 7, 2008 <br /> 001-06750-07-330 <br /> Mark A. Adams, P.G., Trustee <br /> Lincoln Center Environmental Remediation Trust <br /> 137 Park Place <br /> Richmond, California 94801 <br /> Subject: Response to California Regional Water Quality Control Board Letter of June 2, 2008 <br /> RE: Review Of Substrate Injection Completion Report, Phase V Interim Remedial <br /> Action, Lincoln Center, Stockton, San Joaquin County, California <br /> Dear Mr. Adams: <br /> This letter ism response to the California Regional Water Quality Control Board's (RWQCB's) <br /> letter dated June 2, 2008 transmitting its review of LFR Inc.'s (LFR's) "Substrate Injection <br /> Completion Report Phase V Interim Remedial Action," dated April 30, 2008 ("the Injection <br /> Completion Report ) for Lincoln Center ("the Site"), located in Stockton, California. The <br /> aforementioned Injection Completion Report was prepaid in accordance with LFR's final "Phase V <br /> IRA Detailed Plan, Lincoln Center, Stockton, California," dated September 27, 2007 ("the Phase <br /> V IRA Detailed Plan"), as approved by the RWQCB in a letter titled "Review of Draft Proposed <br /> Phase V Interim Remedial Action Detailed Plan," dated November 2, 2007. <br /> The responses presented in this letter were also discussed in our June 16, 2008 conference call <br /> with Mark Adams of the Lincoln Center Environmental Remediation Trust, Marie McCrink of the <br /> RWQCB, and Lucas Goldstein of LFR. For ease of review, LFR has italicized and numbered the <br /> RWQCB's comments below and has responded to each comment. <br /> R�1rQCB Comment 1: <br /> In the ERD Barrier and Treatment Zone Area, data collected from MW-108A suggests a strong <br /> preliminary response to injection from several lines of evidence: increase in Total Organic Carbon <br /> (TOC) concentration; increasing concentrations of trichloroethene (TCE), and cis-1,2- <br /> dichloroethene (cis-1,2-DCE) relative to PCE; decreasing dissolved oxygen (DO) and oxidation- <br /> reduction potential (ORP); and increasing manganese and iron. All lines of evidence indicate that <br /> ERD is occurring in the vicinity of MW-108A located in the center of injection well line. <br /> With the current monitoring program, ERD occurrence can only be documented in the center of the <br /> barrier in one A zone monitoring well. Minimal monitoring of the north and south edges of the <br /> injection barrier for multiple lines of ERD evidence should be added to the program. Although the <br /> agreed upon monitoring program called for monitoring contaminants and daughter products in the <br /> ERD injection wells only after development, it now seems necessary to check one injection well on <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 />