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Mr. Eric Jenks -3- 9 September 2015 zone wells are the wells used to evaluate in-situ bioremediation progress inside the treatment zone (usually 20-foot radius); transition zone wells are the wells used to evaluate migration of pollutants within the transition zone; and the compliance zone wells are the wells used to determine compliance with water groundwater limitation. Therefore, as part of phase 1 injections, Wilbur-Ellis needs to monitor at least one well in each zone. By 9 October 2015, please submit an addendum to the implementation plan with additional groundwater monitoring wells for phase 1. Transition and compliance wells may be selected from the existing network of monitoring wells. 6. The RAW proposes to implement the EISB in two phases. The purpose of Phase 2 is to expand upon phase 1 and fully implement EISB in the shallow and deeper Target Areas. Central Water Valley Board staff concur with this 2-phased approach. However, our recommendation is to cover both the phases under a single General Oder. Therefore, please include both phases and the respective compliance strategy in the same NOI application. 7. Removal Action Goals and RAOs: The overall removal action objective (RAO) for the Site is to reduce concentrations of 1,2-DCP, and 1,2,3-TCP in groundwater both on and off-Site to levels that are protective of human health and to restore beneficial uses of groundwater. This objective is anticipated to be accomplished through the implementation of removal action on- Site, and long term groundwater monitoring on-and off-Site. State or Federal Maximum Contamination Level (MCL) has not yet been established. Therefore, in the meeting on 18 June 2015, it was decided that the final cleanup goals for the Site will be selected following the implementation of the removal action and when long term groundwater monitoring results show declining trends. The RAW proposes to consider regional background of 1,2,3-TCP concentrations and the water quality of the regional groundwater. A background water quality study should be submitted to the Central Valley Water Board if it is JTF's position that the background level for 1,2,3-TCP is not non-detect. In summary, Central Valley Water Board staff conditionally concur with the proposed RAW. Wilbur- Ellis needs to address the comments numbers 3 and 4 and submit an addendum to the implementation plan by 9 October 2015. These revisions should also be included in the NOI application. If you have questions or comments, please contact me at 916-464-4658, or by E-mail at ssewalia(d,)waterboards.ca.gov Siddharth Sewalia Water Resource Control Engineer Private Sites Cleanup Unit cc. Ms. Melissa Schmitt, Geosyntec Consultants, Seattle Ms. Lori Duncan, San Joaquin County Environmental Health Department, Stockton KARL E. LONGLEV ScD, P.E., CHAIR I PAMELA C. CREEDON P.E., BCEE, EXECUTIVE OFFICER 11020 Sun Center Drive#200.Rancho Cordova,CA 95670 1 www.waterboards.ca.gov/centralvalley I p RECYCLED PAPER