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` Em 6.BRom JR. <br /> oorcs <br /> ea��ra■aI• <br /> 860mRlOmaquEa <br /> Water Boards "�"""FOR <br /> Central Valley Regional Water Quality Control Board <br /> 4 April 2013 <br /> Joe Michaud Mark Poe and Robin Stafford <br /> Newark Paperboard Mills Morrison & Foerster LLP <br /> 9 Eno Drive 425 Market Street <br /> Exeter, NH 03833 San Francisco, CA 94105 <br /> DOCUMENT REVIEW, THE NEWARK GROUP, INC. (CASE 2), 800 WEST CHURCH <br /> STREET, STOCKTON, SAN JOAQUIN COUNTY, REGIONAL BOARD CASE 399188 <br /> 1 reviewed the Workplan for Site Investigation Activities (Workplan) received <br /> 2 April 2013 from The Newark Group, Inc. consultant URS. The Workplan was written <br /> in response to my 27 February 2013 letter, which commented on data gaps identified in <br /> the Conceptual Site Model Report(CSM) received 1 February 2013. The Workplan <br /> proposed: <br /> • Collection of shallow 5' below ground surface (bgs) soil gas samples and deeper <br /> 10' bgs soil gas samples near borings B-7 (SG-1 through SG-3), B-14 (SG-4), and <br /> B-15 (SG-5 through SG-7), to evaluate inhalation risks from soil vapor during <br /> redevelopment to construction workers and to future building occupants, <br /> • Collection of 5 additional soil and grab groundwater samples from borings B-42 <br /> through B-46, to further define the lateral extent of petroleum hydrocarbons, <br /> including free product noted in the CSM boring logs near boring B-15, and provide <br /> data for direct exposure risks to construction works, and <br /> • Utilize the soil gas, soil, and groundwater data in a screening level risk assessment <br /> using US Environmental Protection Agency (USEPA) and California Department of <br /> Toxic Substances risk assessment guidance. <br /> A direct push drill rig will install two separate (5' bgs and 10' bgs) temporary soil vapor <br /> probes per soil gas boring location. Soil gas sampling will follow protocols from the <br /> 2010 California Environmental Protection Agency Advisory-Active Soil Gas <br /> Investigations. Soil borings will be continuously cored using a direct push drill rig. Soil <br /> cores will be screened by a photo-ionization detector and by visual and olfactory <br /> observations; and the screening results will be included in the drilling logs. One or more <br /> soil samples will be submitted for laboratory analysis per boring. When groundwater is <br /> encountered (typically 20' to 30' bgs), a grab groundwater sample will be collected for <br /> laboratory analysis. <br /> KAIIL E.LOIaLef SCO,P.E.,GMIR I PAmeIA O.CRaom P.E.,SCEE,ORMITIVE OFFICER <br /> 11 o2a sun G_,w Cf s @=FbnaIO C-d=I%CA MF I www.wmtwbOarda.Oa.Wa•mwltrldvld" <br /> Q RWVCLOO FMiR <br />