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` California Regional Water Quality Control Board Central Valley Region Robert Schneider,Chair Winston H.Hicicox Gray Davis Secretaryfor Sacramento Main Office Governor Environmental Internet Address: http://www.swrcb.ca.gov/rwgcb5 Protection 3443 Routier Road,Suite A,Sacramento,California 95827-3003 Phone(916)255-3000•FAX(916)255-3015 April 30, 2002 Mr. Joseph Salazar, Jr., Attorney at Law i1C I Wd Mayall, Hurley,Knutsen, Smith and Green 2453 Grand Canal Blvd., Second Floor Stockton, CA 95207-8253 PHASE 1 WORKPLAN,REMEDIAL INVESTIGATIONFEASIBILITYSTUDY, FORMER BUSYBEE CLEANERS, 40 N. MAIN STREET, LODI, CALIFORNIA, SAN JOA QUIN COUNTY On March 1, 2002, we held a meeting with you and Mr. Mike Vivas of the Department of Toxic Substances Control (DTSC) at the Regional Water Quality Control Board(RWQCB) to discuss the status of plans for the investigation and remediation of contamination at the former Busy Bee Cleaners site located at 40 North Main Street in Lodi, California. At that meeting, you and other representatives of the property owners indicated a willingness to proceed with investigations at the site under the oversight of the RWQCB. To that end, we have reviewed the submittal entitled"Phase I Workplan, Remedial Investigation Feasibility Study" for the Former Busy Bee Cleaners site prepared by E2C, dated September 5, 2001, which you provided to us at the meeting. Our comments are as follows: 1. We recognize that the work is to be performed in a phased manner. However, the Phase 1 is quite limited in scope. We expect that Phase 2 investigations will be more extensive and will be determined by the results of the Phase 1 investigation. We also expect that the Phase 2 work plan will more closely conform to guidance documents including US EPA's"Guidance for Conducting Remedial Investigations/Feasibility Studies under CERCLA" and Cal-EPA guidance documents entitled"Guidelines for Hydrogeologic Characterization of Hazardous Substance Release Sites" and "Guidance Manual for Ground Water Investigations". 2. A rationale for the locations of the 6 proposed borings should be provided. In addition to a narrative rationale, a map depicted previous sample locations with analytical results posted would be useful. The map should also include sewer line locations, flow directions and locations of known sewer pipe cracks and joints documented through the video inspection of the sewer lines. References to previous reports should be provided. 3. The sanitary sewer lateral emanating from the site as well as the sanitary sewer line located California Environmeiitcal Protection Agency �a Recycled Paper The energy challenge facing California is real. Every Californian needs to take immediate action to reduce energy consumption. For a list of simple ways you can reduce demand and cut your energy costs,see our Web-site at http://www.swrcb.ca.gov/rwgcb5