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AECOMAECOM 2020 L Street,Suite 300 Sacramento,CA 95811 aecom.com July 18, 2023 Our Reference 60632236 Mr. Bill Doerr Greif Inc. 425 Winter Road Delaware, Ohio 43015 Subject: Well Destruction Work Plan for Newark Group, Inc., Central Valley Regional Water Quality Control Board Dopaco Area Case#3, 800 West Church Street, Stockton, California, GeoTracker Global Identification #T10000006482 Dear Mr. Doerr, AECOM Technical Services, Inc. (AECOM)submits this Work Plan for the destruction of the Central Valley Regional Water Quality Control Board (RWQCB) Dopaco Area Case#3 groundwater monitoring wells at the Newark Group, Inc. (Newark)facility at 800 West Church Street, Stockton, California (Site) (Figure 1). This document has been prepared to meet the requirements of the RWQCB letter dated June 12, 2023, (RWQCB 2023a). Site Background The Dopaco Area is in the northwestern corner of the Site. The Dopaco Area was formerly used by Dopaco Inc. for commercial printing operations, and stored printing-related chemicals and waste in eight underground storage tanks (USTs). In September 1986,American Environmental Management Corporation removed the eight USTs. Following removal of the LISTS, soil samples collected from the UST excavation showed the presence of only low levels of five chemicals. In January 1987, Central Valley Water Board and the County of San Joaquin agreed that the tank pits could be backfilled. In 2005, however,Advanced GeoEnvironmental Inc. completed additional investigation which identified elevated concentrations of petroleum hydrocarbons in soil and groundwater in the Dopaco Area and indicated that petroleum fuels (gasoline and diesel)were stored in the USTs prior to Dopaco Inc.'s tenancy at the Site (RWQCB 2023b). Between 2006 and 2022, additional environmental investigations were completed in and around the Dopaco Area and included the collection of soil, soil gas, and groundwater samples.These investigations defined the lateral and vertical extent of the environmental impacts at the Site. In 2014, Geosyntec Consultants removed 320 cubic yards of petroleum-impacted soil from the former UST area and disposed of it at an approved landfill (RWQCB 2023b). In April 2022,AECOM submitted the March 2022 Groundwater Sampling and Site Assessment Report (AECOM 2022). This report documented that soil and soil vapor sampling results satisfied the media- specific criteria for direct-contact, outdoor air exposure, and vapor intrusion to indoor air.As such, the report recommended that the Site be considered low-threat for these criteria. In a letter dated February 2, 2023, RWQCB stated that Site conditions met all the General and Media- Specific criteria established in the California State Water Resources Control Board's Low-threat Underground Storage Tank Case Closure Policy (RWQCB 2023c). Following a 60-day public comment aecom.com Our Reference 60632236 1/6