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