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California Regional Water Quality Control Board <br /> Central Valley Region r r.i!,tP Tia Ai. i( n s <br /> Robert Schneider,Chair <br /> Winston H. Hickox AM (I�Grpy Davis <br /> Secretary for Sacramento Main OfficeJUL vernor <br /> Environmental Internet Address: http://www.swrcb.ca.gov/rwgcb5 <br /> Protection 3443 Routier Road,Suite A,Sacramento,California 95827-3003 <br /> Phone(916)255-3000•FAX(916)255-3015 <br /> 9 July 2003 <br /> Mr. Randy Fischback <br /> The Dow Chemical Company <br /> P.O. Box 1398 <br /> Pittsburgh, CA 94565 <br /> REVIEW OF RESPONSE TO COMMENTS, DOW CHEMICAL (FORMER CELOTEX <br /> CORPORATION), TRACY, SAN JOAQUIN COUNTY <br /> We have reviewed the 3 June 2003 Review of Environmental Assessment (Response to <br /> Comments) submitted by URS Corporation on behalf of The Dow Chemical Company(Dow) for <br /> the former Celotex facility at 400 West Gandy Dancer Drive in Tracy(site). The Response to <br /> Comments responds to Regional Board staffs 21 April 2003 letter with comments on the <br /> April 2003 Environmental Assessment (EA) and provides information not originally submitted <br /> for Regional Board staff review. This information includes the November 2000 Phase I <br /> Environmental Site Assessment(Phase I) prepared by Environmental Resources Management, <br /> material safety data sheets for chemicals stored on the site, and a data diskette not originally <br /> submitted with the EA. The Phase I provides information on operations that occurred on site, <br /> treatment, storage, and disposal of chemicals used in the manufacturing process, underground <br /> utilities, and location of aboveground tanks. <br /> The Phase I addressed a majority of Regional Board staff comments, and we are satisfied with <br /> responses to 10 of the 11 comments. However, the issue of collecting soil vapor samples has not <br /> been adequately addressed. The attached March 2001 letter and site inspection report by the <br /> Regional Board Stormwater Unit lists "dripping of chemicals"near the unloading area near the <br /> pumps and onto railroad ballasts. During the March 2001 site inspection, the Regional Board <br /> staff person believed diethylene glycol was one of the chemicals released. Due to the volatile <br /> chemical nature of many of the chemicals stored on site, we are requesting soil vapor samples for <br /> volatile organic compounds to determine if there have been any releases, as originally stated in <br /> our 6 May 2002 letter. The Response to Comments states that there were no detectable <br /> constituents of potential concern (COPC) in soil and no odors detected during drilling activities. <br /> This is not sufficient evidence to determine if COPCs are in soil vapor. <br /> By 29 August 2003, please submit a work plan to collect soil gas samples from areas of potential <br /> chemical releases to analyze for volatile organic compounds and soil samples for diethylene <br /> California Environmental Protection Agency <br /> �a Recycled Paper <br /> The energy challenge facing California is real. Every Californian needs to take immediate action to reduce energy consumption. <br /> 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 <br />