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MARLEY COOLING TOWER COMPANY <br /> STOCKTON, CALIFORNIA FACILITY <br /> RESPONSE TO WORK PLAN COMMENTS <br /> I. DHS Comments: <br /> DHS Comment: <br /> Page 2-2 First Paragraph; <br /> Comment- <br /> It is the Department's view that installation of the Hypalon <br /> liner may have only reduced the infiltration of liquids into <br /> underlying soil rather than "prevent any further migration" <br /> as stated. The work plan should therefore be revised to <br /> indicate this possibility and to note that the ultimate site <br /> remediation will require a permanent solution for the report <br /> pit. <br /> MCTC Response: <br /> MCTC will comply. <br /> DHS Comment: <br /> Page 3-4 Add the following to list of potential exposure routes; <br /> 4) Direct dermal contact with groundwater. <br /> MCTC Response: <br /> MCTC will comply. <br /> DHS Comment: <br /> Page 3-25 Add the following to bullet items; <br /> o Potential leaching of contaminants into groundwater. <br /> MCTC Response: <br /> This does not represent a data gap. Hexavalent chromium in the <br /> �)yp <br /> vad`o­se—Cz:oiD soil moisture is expected to be capable of moving <br /> 0 into the groundwater. Other wood treating constituents have been <br /> shown to be geochemically immobile and will not leach into the <br /> groundwater. <br /> DHS Comment: <br /> Page 4-1 Section 4.1.1: <br /> First paragraph, first sentence- <br /> Add zinc to list of constituents found to be above <br /> background levels. <br /> 11654 1 <br />