SITE INFORMATION AND CORRESPONDENCE

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Californiaogional Water Quality Con*l Board 01 -W Central Valley RegionRobert Schneider, Chair Linda S.Adams Arnold Secremryfor Sacramento Main Office Environmental 11020 Sun Center Drive 4200,Rancho Cordova,California 956706114 Schwarzenegger Protection Phone(916)464-3291 •FAX(916)464-0645 Governor http://www.waterbowds.ca.gov/cenLralvalley 14 June 2006 JUN 1 6 2006 ENVIRONMEN f HEALTH Ms. Kathleen M. Minahan, Esq. PERMIT/SERVICES Vice President and General Counsel LESCO, Inc. 1301 East Ninth Street, Suite 1300 Cleveland, Ohio 44114-1849 SHALLOW INVESTIGATION WORK PLAN, 2829 AND 2935 WASHINGTON STREET, PORT OF STOCKTON, SAN JOAQUIN COUNTY Lesco, Inc. operated a fertilizer distribution facility at a five-acre site that it leased at 2829 and 2935 Washington Street in the Port of Stockton. Lesco requested Regional Water Quality Control Board (Regional Water Board) oversight as it conducts an investigation on the subject property. Prior to Lesco's tenancy, between 1985 and until at least 1997, Tri-Delta Fertilizer also formulated and distributed fertilizers at this site. A site investigation conducted in 2005 shows that nitrate, ammonium and various other agricultural products are in soil and groundwater beneath the site. As of this writing, there is no commercial activity at the site. Regional Water Board staff received and reviewed the April 2006 Shallow Soil and Groundwater Investigation Workplan (Workplan) prepared by ERM on behalf of Lesco Inc. The Worklan proposes 10 soil/groundwater sample borings arranged along the upgradient and downgradient property boundaries and two borings near the center of the facility where chemicals were detected in the past. The Work Plan From each boring, Lesco proposes to obtain soil samples from the 0-2 feet interval, and from just above the water table. Groundwater samples will be obtained by converting the boring to a temporary one-inch diameter well with a five-foot screen. After a minimum of 24 hours, groundwater elevations will be measured from the wells, and the wells will be purged and sampled. All soil and groundwater samples are proposed to be sampled for inorganic and organic constituents (organochlorine pesticides, organo- phosphate pesticides, chlorinated herbicides, pH, alkalinity, ammonia/ammonium, nitrate, sulfate, chloride, and priority pollutant metals). Regional Water Board Comments The estimate of groundwater flow was made from groundwater elevations obtained in a single event in January 2005. The Workplan states that the rationale for many of the proposed boring locations is to observe concentrations of constituents upgradient and downgradient of the site, and downgradient of previous on-site detections of California Environmental Protection Agency Cd Recycled Paper