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Stephen Donell - 5 - 31 January 2014 c. Catch Basin 5 contained a sand bag. d. Catch Basin 6 (CB 6) identified a "... pipeline going east (Tee intersection)." without identifying the significance of the Tee. e. The Appendix E survey report does not specify if the main warehouse interior trench drain was included in the survey. f. The Appendix E survey report does not provide notes for Catch Basin 7. Staff note that Figure 5 of the Report shows a groundwater mounding effect around Catch Basin 7, therefore this may be a point of recharge and source of contamination. The condition of Catch Basin 7 has to be investigated and reported. g. Unpaved areas along the eastern and southern boundaries of the site, and along the railroad spur on the western boundary, have not been investigated for site contaminants. High concentrations of nitrate are found in wells on both the eastern and western boundary of the site. 6. Section 6.0, Assessment: a. Septic System Area: Regional Board staff do not concur at this time with the Report conclusion that the septic system is not a source of site contamination. Significant site contamination exists without identified source areas. b. UST Graves: Regional Board staff do not concur with the Report conclusion that these areas do not require further investigation or remedial action. The soil contamination needs to be assessed and removed. c. Building Interior: The Report makes no recommendation regarding site conditions in the building interior. At least two patched concrete areas contain significant soil contamination that needs to be assessed and removed. The extent of VOCs in the soil and groundwater need to be defined. Finally, the building drainage features need to be investigated. d. Monitoring Well MW-7: The investigation detected 1,2-DCP and DCBP in the groundwater sample from the well, but makes no recommendation. This well needs to be re-sampled for site contaminants. e. Site-Wide Observations: 1) The Report proposes that arsenic concentrations, although above CHHSLs and EPA Region 9 Screening levels, are within the normal background levels for San Joaquin County and California and does not appear to be a site contaminant. Background concentrations of arsenic should be established with nearby off-site sampling. 2) The Report concludes that VOCs other than 1,2-DCP do not exceed regulatory levels. Regional Board staff do not concur at this time. Additional groundwater sampling is necessary. 3) The Report states that elevated levels of nitrate, chloride, TDS, and sulfate make the water unfit as a drinking water source. Regional Board staff do not