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Working To Restore Nature 1710 Main Street Escalon, CA 95320 Phone: (209) 838-3507 FAX: (209) 838-3509 May 3, 1994 Ms. Pamela Violett San Joaquin County Public Health Services, Environmental Hezlth Div'.sion P.O. Box 2009 Stockton, CA 95201 Subject: Courtyard vault closure at Newark Sierra Paperboard Corp., 800 W. Church St., Stockton, CA Dear Ms. Violett: As we discussed over the phone today, I am writing to offer my recommendations regarding closing the abandoned pipelines associated with the vaults at the subject site. Based on my observations at the site and correspondence with Mr. Rogge of Newark Sierra (see attached letter) it is my opinion that it would be extremely difficult, if not impossible, to delineate the routing of these pipes. Such an effort would also involve inordinate delay and expense. Due to the surface/subsurface congestion in the vicinity of the vaults, pipeline tracing by geophysical means would probably be ineffective. The deteriorated condition of the pipes would likely result in leakage of any gas that was introduced as a tracing method. Likewise, the pipes could rupture at unpredictable locations if cement slurry were to be pumped into them. For these reasons, I recommendend that the pipes be sealed by plugging the exposed openings with concrete and welding steel caps over the ends. These measures should be sufficient to ensure that the abandoned pipes leading to/from the former vaults do not act as conduits in the future. I know we are all anxious to close the vaults just as soon as possible. Your favorable review of the above recommendation would be greatly appreciated. If you have any questions or comments please call me at your earliest convenience. Respectfully, RESNA Industries, Inc. Gregory P. Stahl, CA Registered Geologist No. 5023 attachment pc: Mr. Mike Rogge, Newark Sierra Paperboard Corp.