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EDI,UPg., C. Elnotv., <br />'11;1; OPv2ANOH <br />1/4;18; <br />MATMEW RODMOUE: <br />SLIVIE WO' ;OL <br />ENVIIONAIENT, Pr101,7,1(11. Water Boards <br />Central Valley Regional Water Quality Control Board <br />6 September 2016 <br />Min Le <br />McBillin Real Estate Investment <br />3293 Napa Drive <br />San Jose, CA 95148 <br />IVIcBILLIN REAL ESTATE INVESTMENT, 2154 SOUTH EL DORADO STREET, <br />STOCKTON, SAN JOAQUIN COUNTY, CASE# 391184 <br />On behalf of the Central Valley Regional Water Quality Control Board (Central Valley Water <br />Board), I am pleased to notify you that as of 1 June 2.016, I am the assigned caseworker for <br />the underground storage tank release at the McBillin Real Estate Investment property in <br />Stockton. My contact information is included at the end of this letter. <br />I have reviewed the following documents, submitted on your behalf by Advanced <br />GeoEnvironmental Inc. (AGE) for your property at 2154 South El Dorado Street in Stockton <br />(Site): <br />Work Plan Addendum (Soil Gas Work Plan), dated 29 July 2016 <br />Monitoring Well Installation Work Plan Addendum — August 2016 (Monitoring Well <br />Work Plan), dated 8 August 2016 <br />In the Soil Gas Work Plan, AGE proposes the installation and sampling of three soil gas <br />wells: one in the Site source area (former tanks), and two along the eastern property <br />boundary, near neighboring residences. In the Monitoring Well Work Plan, AGE proposes <br />the installation of two deep monitoring wells down-gradient: one in the gravel road at the east <br />edge of the Site property, and one approximately 600 feet east of the Site source area; both <br />to be screened 90-100 feet below ground surface (bgs). <br />Additional assessment is needed at this Site, beyond what is proposed in these two Work <br />Plans, and a Work Plan Second Addendum is requested. Below are my comments on the <br />submitted Work Plans, and on the status of the assessment of the petroleum release from <br />the Site: <br />1 The soil gas wells proposed in the Soil Gas Work Plan are intended to be "semi- <br />permanent", and the annular seals are proposed to consist of hydrated bentonite. <br />However, in accordance with the July 2015 Department of Toxic Substances Control <br />(DTSC) guidance document Advisory — Active Soil Gas Investigations, soil gas wells <br />constructed with a bentonite annular seal can be used for no more than 1 year. <br />Permanent soil gas wells should be installed to allow for repeatable soil gas sampling <br />in the future. Per DTSC guidance, permanent soil gas wells should have an annular <br />seal consisting of neat cement with a bentonite content of 1-5%, and a six-inch <br />KARL E. LONGLEY ScD, P.E.. CHAIR I PAMELA C. CREEDON P.E., BCEE. EXECUTIVE OFFICEP <br />11020 Sun Center Drive 4200, Rancho Cordova, CA 95670 I wwv,waterboards.ca.govicentralvalley <br />PECYCLCD PAPE.