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� ',,.,w s�;.R � ® e r EDMUND G. BROWN JR. C ECE'� OOVEPNOR .h C r I t O P M r♦ JUL 15 2014 0 MCRr TARP FOR DRIOUEZ WaterBoards v FNVIRDNMFNTAI PROT-TION FAI 1H Central Valley Regional Water Quality Control Board PERMIT/SERVICES 11 July 2014 Joe Michaud Mark Poe and Robin Stafford Newark Paperboard Mills Morrison & Foerster LLP 9 Eno Drive 425 Market Street Exeter, NH 03833 San Francisco, CA 94105 SUPPLY WELL VIDEO AND SAMPLING RESULTS,- GROUP,INC., 800 WEST CHURCH STREET, STOCKTON, SAN JOAQUIN COUNTY The California Regional Water Quality Control Board, Central Valley Region (Central Valley Water Board) staff reviewed the 27 June 2014 Supply Well Video Survey and Groundwater Sampling Results Report with Workplan for Well Purging and Destruction at the Newark Group, Inc., Petroleum Site (Report), submitted on your behalf by URS Corporation (URS). URS reported removal of well pumps and piping from four of five on-site water supply wells. Subsequent to removal, video logging and sampling was performed to determine construction details and the conditions of five existing water supply wells on the property at 800 West Church Street. Two of the wells exhibited concentrations of petroleum hydrocarbons in the water samples collected during this field effort. URS proposes to purge up to 20,000 gallons of water from the two supply wells (wells#2 and #3) which contained petroleum constituents prior to destruction of all five wells. I concur with the proposal to properly destroy the five water supply wells but do not concur with the proposal to purge wells #2 and #3 prior to destruction. In the Report, URS describes video logging of five on-site water supply wells. The video camera was able to assess the total depth of two out of the five wells surveyed. With the exception of Well #2, which showed perforations from 211- 272 feet below the ground surface (bgs), all of the wells appear to have been constructed with solid casing. In general the wells are in poor condition, highly corroded and open at the ground surface. URS reported collecting water samples from each of the water supply wells. In the text of the Report, URS states that "the submersible pump was placed at a depth of 100 feet bgs for purging..." and then "Samples were collected from the groundwater exiting the tubing as it continued to be pumped from the well." However, Figure 2 in the Report indicates the groundwater samples were collected between 16 -19 feet bgs. Although the discrepancy in where the samples were collected may be confusing, because the wells were constructed of solid casing and various holes and cracks are apparent in the casings, the depth the sample results represent are suspect. USR identified seven (7) water supply wells in its Workplan for Site Investigation Activities dated 29 October 2013. Figure 4 showed the location of the supply wells and the construction details were described in Table 2 (Figure 4 and Table 2 are attached). URS states in the Workplan that KARL E. LONGLEY SCD, P.E., CHAIR I PAMELA C. CREEDON P.E., BCEE, EXECUTIVE OFFICER 11020 Sun Center Drive#200,Rancho Cordova,CA 95570 I www.waterboard S.Ca.gov/centralvalley i,nr.CYCEED rAr