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Dopaco, Inc. -4 - 24 July 2013 800 W. Church St., Stockton San Joaquin County 3. In the Report, GC states additional soil gas characterization is needed to evaluate potential vapor intrusion to indoor air, due to high sub-slab levels of toluene and benzene detected prior to building demolition. In addition the CSM shows the six former underground tanks extending south of the pump house area (see Figure 5, attached). Additional soil vapor sampling should be proposed to verify the property is suitable for redevelopment and that all tanks previously operated and removed from the Site have been adequately investigated. 4. Under the Stipulated Injunction and Consent Decree, dated 20 April 2012 Dopaco, Inc. was to submit the Investigative Work Plan within 90 days of the signing of the Court Decree, which is long overdue. Our reading of the Court Decree then orders Dopaco to complete work described in the Investigative Work Plan and submit a proposed Remedial Work Plan within nine months of the Water Board's approval of the Investigative Work Plan. Although the dates for submission of the Investigative Work Plan have been exceeded, we can support the requirement for the results of the Investigative Work Plan and the proposed Remedial Work Plan be submitted within the allotted 90 days. Therefore the results from the Investigative Work Plan and the proposed Remedial Work Plan should be submitted no later than 25 October 2013. The proposed Remedial Work Plan must address our comments above pertaining to installation of depth- discrete groundwater monitoring wells, and additional soil and soil vapor sampling. Sampling for the expanded list of analytes should be incorporated into the Investigative Work Plan and be included in the results. 5. Please note in the future, all documents must be submitted and received in hard copy at least 30 days prior to any Court Decree deadlines, to provide adequate time for my review and response. 6. To date I have not received a paper copy of the Addendum. Please submit the paper copy of the Addendum to this office as soon as possible. 7. Groundwater monitoring at this Site may be reduced to semi-annual and reports should be submitted during the first and third quarters of each calendar year. Groundwater Monitoring reports are due on the 30th day of the month following the quarter. The next monitoring report is due 30 October 2013. 8. Please submit the results of the Investigative Work Plan and the proposed Remedial Work Plan by 25 October 2013. We are currently reevaluating the language in the Court Order, specifically number 5, on page 2, which states "Dopaco shall contact the Regional Board and enter its voluntary clean-up program, including payment of the Water Board's oversight costs" with our legal counsel to determine if this case may continue to be reviewed by staff in the Underground Tank Program. We hope to receive advise on this issue before review of the Remedial Work Plan is needed.