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/4 �e <br /> California&gional Water Quality Conirl Board <br /> \� Central Valley Region <br /> Karl E.Longley,ScD,P.E.,Chair <br /> Linda S.Adams Arnold <br /> Lin <br /> SS. ar Sacramento Main Office Schwarzenegger <br /> Environmental 11020 Sun Center Drive 9200,Rancho Cordova,California 95670-6114 Governor <br /> Protection Phone(916)464-3291 •FAX(916)464-4645 <br /> M1ttp://www.waterboardsnna.gov/centrall5allfey 5 <br /> 13 February 2008 WECIFuUFD <br /> FEB 15 2008 <br /> Mr. James Nitzschke ENVIRONMENT HEALTH <br /> Deere & Company PERMIT/SERVICES <br /> One John Deere Place <br /> Moline, IL 61265 <br /> CONCURRENCE WITH SITE CHARACTERIZATION WORK PLAN, FORMER LESCO SITE, <br /> 2829 W. WASHINGTON STREET, SAN JOAQUIN COUNTY, CA <br /> In August of 2007, Deere and Company purchased Lesco Inc., and agreed to take over <br /> investigation and remediation of a former Lesco facility at the Port of Stockton, in California. <br /> The site has been operated as a fertilizer distribution facility for many decades. Prior to 1987, <br /> Delft Fertilizer was the operator, between 1987 and the late 1990s the facility was operated by <br /> Tri-Delta Fertilizer, then Lesco operated the facility until 2005. In 1998, old unlined stormwater <br /> ponds were excavated and backfilled, and a new clay-lined pond was installed. Lesco initiated <br /> soil and groundwater investigation in January 2005. The facility has been inactive since 2005. <br /> Central Valley Regional Water Quality Control Board (Regional Water Board) staff reviewed <br /> the October 2007 Additional Site Characterization and Monitoring Well Installation Workplan <br /> (Work Plan) provided by Deere and Company's consultant, ERM. The Work Plan proposes to <br /> install four monitoring wells in strategic locations, conduct aquifer characterization analyses, <br /> conduct four quarters of groundwater sampling, and evaluate the effect of tidal influence on <br /> the groundwater surface. The Work Plan incorporates the elements requested in Regional <br /> Water Board staffs 31 January 2007 letter. <br /> Work Plan Comments <br /> Regional Water Board staff conceptually concur with the Work Plan, and respectfully request <br /> the following adjustments and additions. <br /> Proposed monitoring well MW-1 is positioned along the mid-point of the western boundary. <br /> Deere and Company should locate this monitoring well further south, to coincide with the <br /> former stormwater pond that was located between the former mixing area and the western <br /> levee. <br /> Soil borings are proposed to be obtained from the surface to either groundwater or to 12 feet <br /> below ground surface, whichever is encountered first. From the borings, two soil samples <br /> from continuous cores will be logged, sampled, and analyzed for bulk density, porosity, soil <br /> moisture content, grain size distribution, and a soil description. A sample of cohesive soil will <br /> be analyzed for permeability. In previous investigations, groundwater was encountered at <br /> California Environmental Protection Agency <br /> cc1 Recycled Paper <br />