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Dear Kyle McCormack and Brian Millman, <br />Thank you for submitting the January 7, 2023, San Joaquin Cogeneration Site Investigation Report (2023 <br />Report). The 2023 Report reflects the findings of the December 10, 2021, Site Investigation Work Plan <br />and the additional investigation concurred upon on September 30, 2022. <br />In the San Joaquin County, California Department of Resources Recycling and Recovery's (Cal Recycle) <br />and Region 9 Environmental Protection Agency (EPA) site visit on March 15, 2023, EPA observed the <br />following areas that may require further investigation: <br />1. In the transformer yard area, carved channels may act as conduits for contaminants to migrate on <br />the site. (Fig 1 & 2; Near boreholes: 50, 51) <br />2. Between the southern and northern portion of the property, the grading of the road sloped to the <br />east, in the direction of the adjacent Tesla property, may lead to migration of contaminants <br />towards the drainage trench that lines the eastern boundary of the property. (Figure 3 & 4; Near <br />borehole: 67) <br />3. Not photographed, the concrete pillar -like structure in the south-western portion of the property <br />may act as a conduit for subsurface -migration at depth of contaminants. (Near borehole: 163, <br />164) <br />Additional observations of the conditions of the site include: <br />A. Glass waste is observable on the surface of most of the site. <br />B. Fencing around the perimeter was incomplete and/or damaged. EPA recommends that the fence <br />be repaired to prevent unauthorized access to the site. <br />C. Google 2012 Imagery shows the south-western portion of the site was exposed and the corner of <br />the property was used as a vehicle turn -around location. The western border of the property has <br />been landscaped since and prevents vehicles from accessing the property (Figure 5 & 6) <br />The 2023 Report records bore -hole sample that indicates the presence of contaminants near some of the <br />site findings that may require further investigation. The Conclusions and Limitations sections (9.0 & 10.0) <br />reflect a certain level of uncertainty as to the subsurface conditions away from the collected data points. <br />The 2023 Report should be amended to reflect uncertainty involving the identified concerns addressed <br />above. <br />Thank you, <br />Alexis Illich, EPA <br />