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California Regional Water Quality Control Board <br /> Central Valley Region <br /> Robert Schneider, Chair <br /> Arnold Schwaaeaegger <br /> Terry Tamminea <br /> Secretary for Sacramento Main Office Governor <br /> Environmental Internet Address: http://w .sv b.ca.govtwgcb5 <br /> Protection 11020 Sun Cenw Drive#200 Rancho Cordova.CA 95670-6114 <br /> Phone(916)464-3291 Fax(916)464-4797 <br /> 21 May 2004 <br /> Mr. Kyle Rutherford <br /> Union Oil Company of California <br /> P.O. Box 1069 <br /> San Luis Obispo, CA 93406 <br /> REVIEW OF RESPONSE TO COINDIENTSXWESTIGATION WORKPLAN,SOUTH SHORE <br /> PARCEL 2A, UNOCAL OPERABLE UNIT, STOCKTON, SAN JOAQULN COUNTY <br /> Staff of the Central Valley Regional Water Quality Control Board (Regional Board) has reviewed the <br /> 16 January 2004 Response to Comments/Investigation Workplan (Work Plan) submitted by Clayton <br /> Group Services on behalf of Union Oil Company of Cali <br /> Work Plan was submitted in response <br /> y f°or the South <br /> Shore Parcel Parcel 2A Unocal Operable Unit (OU). <br /> Regional Board staff's 19 December 2003 letter,which commented on the 3 December 2003 Interim <br /> Remedial Action Workplan (December Work Plan). Based on discussions with Mr. Morgan Gilhuly, <br /> attorney representing the Unocal OU, review of the Work Plan was placed on hold until the Unocal OU <br /> could obtain a Voluntary Cleanup Agreement (VCA) with the Department of Toxic Substances Control <br /> for oversight of a health risk assessment(HRA). The HRA is important to the proposed remedial <br /> activities to establish health risk based cleanup levels for contaminants in soil. During a 17 May 2004 <br /> phone conversation, you stated that work is proceeding to complete the VCA,but the Unocal OU wants <br /> to move forward with the proposed interim remedial activities,with the understanding that no soil <br /> cleanup levels have been determined. <br /> In addition to the work proposed in the December Work Plan, the Unocal OU also proposes 22 borings <br /> to collect soil and grab groundwater samples to fill data gaps and use the results to determine designated <br /> and health risk cleanup levels. Regional Board staff concurs with the Work Plan, and the responses <br /> adequately address our comments. By 10 September 2004, please submit an investigation report that <br /> details field activities and sampling results. Unocal OU needs to notify Regional Board and DTSC staff <br /> a minimum of 72 hours prior to beginning the proposed excavation and investigative activities. If you <br /> have any questions, you may contact me at (916) 464-4719 or lewisd@rb5s.swrcb.ca.gov. <br /> DEVRA I EWIS <br /> Environmental Scientist <br /> cc: See Page 2 <br /> California Environmental Protection Agency <br /> ed Recycled Paper <br />