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KLEINFELDER <br />Bright People. Right Solutions. <br />November 2, 2017 <br />Kleinfelder Project No. 20173951.001A <br />Amy Ha, PE <br />Water Resources Control Engineer <br />Private Site Cleanup Unit <br />Central Valley Regional Water Quality Control Board <br />11020 Sun Center Drive, Suite 200 <br />Rancho Cordova, CA 95670-6114 <br />Sent Via email (Amy.Ha@Waterboards.ca.gov) <br />SUBJECT: Closure Work Plan <br />APN 022-125-035, <br />407 Spreckels Avenue <br />Manteca, California <br />Dear Ms. Ha: <br />Thank you for meeting with us (Kleinfelder) on October 2, 2017 to discuss our efforts to close the <br />open Spills, Leaks, Investigation, and Clean-up (SLIC) case for the Spreckels site (Site, Figures <br />1 and 2). This letter formalizes the closure plan that we discussed. We have broken the Site into <br />Operable Units (OUs) that directly correspond with the Recommendations and Sub- <br />Recommendations referenced in previous communications (Figure 3). This closure plan explains <br />each Operable Unit and summarizes Phase I findings, Phase II sampling analyses and results, <br />recommended further action (if any), anticipated results, and details our work plans. This closure <br />plan was the result of detailed analyses, and it incorporates recommendations and insights from <br />our October 2, 2017 meeting. We look forward to further coordination if efforts to close this Site <br />as quickly as possible. <br />Kleinfelder applied for a Memorandum of Agreement (MOA) and Request for Agency Oversight <br />with the Regional Water Quality Control Board (Board) SLIC Unit. The application applies to a <br />14.83-acre, undeveloped parcel of industrial-zoned land (Site) located at 407 Spreckels Avenue <br />in Manteca, California. A Phase I related to the pending sale of this Site revealed an open SLIC <br />case, which the buyer has requested be closed prior to purchase. Kleinfelder is aiding the current <br />owner (AKF Development Holdings LLC [AKF]) in reviewing past investigations, obtaining <br />regulatory oversight, and ultimately obtaining closure. <br />Kleinfelder was contacted by AKF because Kleinfelder conducted initial Phase I investigations <br />and Phase II sampling for this Site starting in 1997, when the general area was being developed. <br />This Site was part of the former Spreckels sugar-processing factory. AKF acquired the land <br />associated with the larger sugar-processing factory for development, and Kleinfelder conducted <br />factory-wide Phase I investigations and Phase ll sampling and analyses. <br />San Joaquin County provided regulatory oversight, and Kleinfelder worked closely with their <br />regulators to direct Phase II investigations, analyses, and remedial events in order to gain closure. <br />20173951.001A/SAC17R68420 Page 1 of 26 November 2, 2017 <br />@ 2017 Kleinfelder www.kleinfelder.com <br />KLEINFELDER 2882 Prospect Park Dr., Suite 200, Rancho Cordova, CA 95670 p I 916.366-1701 f I 916.366-7013