SITE INFORMATION AND CORRESPONDENCE

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Peter, have your work plan, but I don't have an application for the permit as of yet, or the fees that go with it. I do not anticipate a great deal of time will be required to issue the permits, but please allow at least 5 working days from receipt of the documents and Regional Board's approval of the work plan for me to fit it into my workload, although it usually takes only two or three days. Although the central Valley Regional Water Quality Control Board is now the lead agency, I have been reviewing the materials submitted to complete our files for the site and I have results for borings 61 through B4 (4/22/15), B5 and B6 (2/10/16), 611 and 612 (2/19/2016), and B20 through B22 (6/19/15). The only borings advanced under permit were 61 through B4. I don't understand the odd dates for the later group (dates taken from the lab reports), but the gaps in the boring designations makes me wonder if there were also borings B7 through 610 and 1317 through 619; are there such borings? If so, please 4AfL forward the results to me and of course to Brad Shelton. I would also appreciate a site map showing all VIP the sampling locations, particularly B1 through B4 where groundwater samples had been obtained. This information will complete my file and fulfill the requirement to provide the Environmental Health Department(EHD)with the results of your investigation noted on the Master File Record form for the V G� permit for the first four borings. In future, the EHD requests only electronic copies of future work to stay up to date on the site status. ;r �_Oo OAAC4 V y rdW 0-'r- On behalf of my colleagues at the Regional Board, I think it is unfair to imply that their lack of immediate f approval of your work plan within a month of taking on the case may have let the release impact groundwater, thereby leading to a greater problem and higher costs. Had the regulatory agency been brought into the investigation when the problem was first recognized, they would have been up to speed at this point and the turn-around time for work plan approval greatly shortened; as it is, they have to work it into their work load with numerous other projects currently in progress competing for their time and attention. Nothing presented to date indicates an immediate and significant threat to human health or the environment that demands their immediate attention; in fact the reports issued by your firm seem to minimize the significance of a potential impact by the release with such statements as During a Site visit on May 12, 2015, GHD staff observed minimal staining on a former concrete transformer pad that extended onto a small amount of soil adjacent the pad. and Although there was no way to know if a reportable quantity (RQ) of chemical had been exceeded in the release, based on the small staining observed and the small quantities of oil that would be released from a cut transformer coolant line, it is unlikely that an RQ was exceeded when the vandals stole the transformers. These statements don't seem to go with the extreme urgency you now imply. This is not to say that groundwater has not been impacted or that the release need not be properly investigated and appropriate corrective actions taken, but it seems unlikely that any impact to groundwater is the result of not approving your work plan during the last month. The staff of the Regional Board are highly professional people who take their mission and responsibilities seriously and I'm sure will respond to your requests in a timely and appropriate manner. Nuel Henderson Engineering Geologist (209) 468-3436 From: Masson, Peter [mailto:Peter.Masson@ghd.com] Sent: Monday, May 09, 2016 2:51 PM To: Mello, Joe@Waterboards; Meeks, Steven @Waterboa rds