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CONDOR EARTH TECHNOLOGIES,INC. <br /> 188 Frank West Circle,Suite I <br /> Stockton,CA 95206 <br /> Phone 209.234.0518 <br /> x Fax 209.234.0538 <br /> CONDORwww.condorearth.com <br /> December 22, 2015 <br /> Aimee Phiri,P.E. <br /> Central Valley Regional Water Quality Control Board <br /> 11020 Sun Center Drive#200 <br /> Rancho Cordova,CA 95670 <br /> SUBJECT: Review Comments for Revised Site Investigation Work Plan, Former Helena Chemical <br /> Facility,2245 West Charter Way, Stockton, San Joaquin County <br /> Condor Job No. 6847 <br /> Dear Ms. Phiri: <br /> Condor Earth Technologies, Inc. (Condor) reviewed the Central Valley Regional Water Quality Control <br /> Board(CVRWQCB)comments to the September 10,2015 letter reviewing the Revised Site Investigation <br /> Work Plan,Former Helena Chemical Facility, 2245 West Charter Way, Stockton,California(Work Plan) <br /> submitted June 2015. Below you will find the CVRWQCB's comments and Condor's responses <br /> underlined below the comment. In addition, Condor and CVRWQCB staff participated in a conference <br /> call on December 3,2015 in order to discuss the comments and agree on an approach detailed below. It is <br /> Condor's opinion that this second revision to the Site Investigation Work Plan reflects our mutually <br /> agreed approach and respectfully requests that the CVRWQCB approve this work plan to move the <br /> project forward. <br /> GENERAL COMMENTS <br /> 1. The Site is outside the jurisdiction of the San Francisco Bay Regional Water Quality Control <br /> Board (Region 2). Therefore, the Region 2 Environmental Screening Levels (ESLs) are not <br /> applicable to the Site.Please revise the Work Plan to remove references to Region 2 ESLs. <br /> References to Region 2 ESLs have been removed. <br /> 2. The Water Quality Control Plan(Basin Plan) for the Sacramento and San Joaquin River Basins, <br /> adopted by the Central Valley Regional Water Board, designates all groundwater as suitable for <br /> municipal and domestic uses (including drinking). Therefore, water quality objectives (WQOs) <br /> that are protective of drinking water are applicable for the Site. To be protective of drinking <br /> water, the WQO for each chemical constituent at the Site is set at the most limiting value of <br /> applicable water quality limits (i.e. primary maximum contaminant level [MCL], secondary <br /> MCL, public health goal [PHG], or notification level) for that chemical constituent. Please select <br /> a laboratory that can perform analyses using the lowest commercially available and achievable <br /> reporting limits (RLs), to provide quantification of constituents for evaluation with respect to the <br /> Site's WQOs. <br /> Condor began the process of selecting a laboratory by contacting Jane Jensen of the State of <br /> California Water Quality Control Board Environmental Laboratory Accreditation Program <br /> (FLAP). Jensen provided a list of laboratories that were accredited to perform analysis of 12.3- <br />