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-aEowRwo G.BROM JR. <br /> oeYnwa <br /> ew��re•a�w � �TTMF1 Rev�quez <br /> Water Boards <br /> Central Valley Regional Water Quality Control Board <br /> 24 July 2013 <br /> Leon Marineau Christian L'Orange <br /> Cascades Inc. Drinker Biddle & Reath LLP <br /> 471 Marie-Victorin 50 Fremont Street <br /> Kingsey Falls, Quebec, Canada JOA 180 San Francisco, CA 94105 <br /> DOPACO, INC., 800 WEST CHURCH STREET, STOCKTON, <br /> SAN JOAQUIN COUNTY, REGIONAL BOARD CASE 391187 <br /> California Regional Water Quality Control Board, Central Valley Region (Central Valley Water <br /> Board) staff reviewed the CPT-13 Area Investigation Report (Report) and Work Plan (Work <br /> Plan) dated 3 June 2013, submitted on behalf of Dopaco, Inc. by Geosyntec Consultants (GC). <br /> also reviewed the Addendum 1 to CPT-13 Area Investigation Report and Work Plan <br /> (Addendum) uploaded to the State Water Board GeoTracker database by GC on 28 June 2013. <br /> We are aware Dopaco has been ordered to conduct investigation and cleanup of toluene, and <br /> any chemicals commingled with toluene, from the property at 800 West Church Street in <br /> Stockton by agreements specified in the Stipulated Injunction and Consent Decree per United <br /> States District Court, Eastern District of California Case 2:08-cv-02623-GEB-DAD, dated <br /> 20 April 2012 (Court Decree). <br /> We concur with the work proposed by GC in the Work Plan and Addendum with the following <br /> conditions; <br /> • Permanent, depth- discrete monitoring wells will need to be proposed and constructed to <br /> delineate and monitor concentration trends of the groundwater impacts horizontally and <br /> vertically for all chemicals of concern. <br /> • Additional soil and soil vapor samples will be needed in the area previously below the <br /> building identified as an area of concern in 2011 prior to building demolition and south of <br /> the pump house area. <br /> • The list of chemicals of concern must be expanded to include naphthalene, benzene and <br /> xylenes. <br /> GC provided soil and groundwater results of the March 2013 investigation of the CPT-MIP- <br /> 2013-13 area, a conceptual site model (CSM) for the toluene release from underground storage <br /> tanks (USTs) and an evaluation of the Site using the State Water Board's Low Threat Closure <br /> Policy (LTCP). GC presented drilling logs and geologic cross-sections showing the water table <br /> underlying the Site occurs at approximately 14' below ground surface (bgs) in a fine-grained silt <br /> KARL E. LaRattr BCD,P.E.,CHAIR I PAMELA C.CREEOOlI P.E.,SCEE,maxa Ve OFFICER <br /> 11024 Burt Carrow OAra f244.Rambo Cardwa.CA OWN I www.watwbemrda.ea.gwdcwrftyalleV <br /> to RGCYCLiO PAPiR <br />