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California Regional Water Quality Control Board Central Valley Region Robert Schneider,Chair Winston H. Hickox Gray Davis Secretaryfor Sacramento Main Office Governor Environmental Internet Address: http://www.swrcb.ca.gov/rwgcb5 W Protection 3443 Routier Road,Suite A,Sacramento,California 95827-3003 n. __,_L Phone(916)255-3000•FAX(916)255-3015 -r: N � ' (J t Y 21 April 2003 ---T cn n Mr. Randy Fischback r The Dow Chemical Company P.O. Box 1398 Pittsburgh, CA 94565 REVIEW OF ENVIRONMENTAL ASSESSMENT, DOW CHEMICAL (FORMER CELOTEX CORPORATION), TRACY, SAN JOAQUIN COUNTY We have reviewed the April 2003 Environmental Assessment (EA) submitted by URS Corporation on behalf of The Dow Chemical Company(Dow) for the former Celotex facility at 400 West Gandy Dancer Drive in Tracy(site). The EA discusses the site's physical setting, background, and areas of concern and describes the results of investigative activities, including the installation of four monitoring wells. The EA recommends completing an additional round of groundwater monitoring to determine whether groundwater has been polluted by site operations. We have the following comments on the EA: 1. The EA is not signed or stamped by a URS representative to show that the work was performed by or under the supervision of a registered professional as is required by the California Business and Professions Code Sections 6735, 7835, and 7835.1. All reports must include a signature and stamp from the registered professional. 2. The EA includes a summary of the chemicals stored on-site but does provide a discussion of what the chemicals are (i.e., R-22 and HCFC-141-B), what constituents make up the material (i.e., di-isocyantes, polyol, catalysts, and printing inks), or where the chemicals were specifically stored on site. Furthermore, there is no discussion of how the analytical methods for the soil and groundwater sampling were selected and if those methods would determine if there is pollution originating from site operations. Dow needs to explain how the chemicals are transferred to the storage containers, describe the chemicals used and stored at the facility, and discuss the rationale for the analytical methods used to test soil and groundwater samples. California Environmental 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