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Bill Filios 3 <br />21 November 2017 <br />Operable <br />Unit No. <br />Constituents <br />of Concern Proposed Evaluation <br />11 <br />Petroleum-related <br />Collect and analyze 7 passive soil gas, 6 soil and <br />2 groundwater samples for Total Petroleum Hydrocarbons, <br />VOCs, and Solvents. <br />Metals Collect and analyze 6 soil and 2 groundwater samples for <br />CAM 17 Metals. <br />Pesticides/ <br />Herbicides <br />Collect and analyze 7 passive soil gas, 6 soil and <br />2 groundwater samples for Pesticides and Herbicides. <br />Central Valley Water Board Comments <br />Central Valley Water Board staff comments are summarized below: <br />1. Site Evaluation: As discussed with the Bill Filios of AKF Development LLC. and <br />Anthony Wohletz and Steve Weisner of Kleinfelder on 13 November 2017, there are <br />various conclusions and information in the Closure Work Plan that do not have the <br />supporting documentation referenced or included to substantiate the conclusions. A few <br />examples are shown below: <br />The references for the information presented in the tables and figures are not <br />included in the report. <br />The conclusion that "Down/cross-gradient Hydropunch data, however, do not <br />indicate petroleum-related contamination" does not detail what hydropunch <br />information is being referred to. <br />The conclusion that "These values do not indicate leaks of acidic or basic <br />solutions" does not include any rational for why the data results support this <br />conclusion. <br />The Central Valley Water Board cannot concur with conclusions without the supporting <br />information included in the report or referenced. Central Valley Water Board staff's <br />concurrence with the proposed scope-of-work for additional site investigation does not <br />constitute Central Valley Water Board concurrence with the data analysis conclusions <br />presented in the Closure Work Plan. <br />2. Petroleum Related Constituents - The Central Valley Water Board staff do not agree <br />that solvents and volatile organic compounds (VOCs) not related to petroleum should be <br />evaluated as petroleum related constituents. The Report of Findings will need to include <br />a separate evaluation for solvents and VOCs that are not related to petroleum. <br />3. Background Soil Samples: If background soil metal concentrations cannot be <br />determined from existing literature sources, Kleinfelder proposes to collect five, <br />randomly selected, soil samples to assess background metals concentrations. If <br />background soil collection and analysis is required, the Report of Findings shall include <br />the rational for the number of background soil samples collected to support their <br />conclusions. Additionally, background analyses for hexavalent chromium may be <br />required to complete the Discharger's proposed evaluation of trivalent chromium versus <br />hexavalent chromium. <br />4. Spot Check Existing Data: Numerous previous investigation results were reported as <br />non-detect; however, it is not known if the reporting limits are above the current