ARCHIVED REPORTS_REPORT SUMMARIZING INSTALL OF MONITORING WELLS MW4,MW5,MW7,MW8 & SOIL BORING RDM1 & 4TH QTR 2013 GROUNDWATER SAMPLING

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E.G.64M1 JR. •G, a aa,• � �4rTR1EA Rnmquez Water Boards r�R exvwRacru vrors� Central Valley Regional Water Quality Control Board 22 May 2013 Angela Lee Huntbrook Holdings, LLC 2351 Sunset Blvd., #170-717 Rocklin, CA 95765 • STAFF LETTER REVIEW AND RESPONSE, E&R FREEMAN, 3138 E. MAIN STREET, STOCKTON, SAN JOAQUIN COUNTY(CASE 390328) On 1 May 2013, 1 reviewed a copy of the cost pre-approval letter (Letter) that Huntbrook • Holdings, LLC received from the State Water Resources Control Board (SWRCB), Technical Review Unit of the Underground Storage Tank Cleanup Fund (Fund). The Letter acknowledged that the Regional Board (staff) had approved the scope of work covered in the Letter pre- approval; however, there were several inaccurate statements in the Letter that resulted in no funding for specific tasks, namely under Task 9 Remedial Testing Activities; Task 10 Remedial • Testing Results Report, and Task 11 Corrective Action Plan/system Design. The Letter Comment(s) section for each of the tasks state "The site needs to be evaluation (sic) under the Low Threat Closure Policy prior to initiating remediation efforts." I completed/finalized the Low Threat Closure Policy (LTCP) Checklist on the SWRCB GeoTracker website for your case on 27 March 2013, which is/was available for review by Fund staff, more than 30 days prior to the • date of the Letter. I concluded for multiple reasons, also stated in my letter dated 13 February 2013, that your case does not pass the LTCP. My letter on GeoTracker also stated that an additional soil and groundwater investigation was necessary to complete the offsite investigation, and approved a pilot study, which is necessary to demonstrate that the proposed remedial action at the dispenser island source area would be effective at full scale, if warranted • by the data. In order to provide the Fund with additional assurance that there is sufficient contamination in soil and groundwater to warrant the above pilot study, the soil investigation of the dispenser island source area under the building-covered former dispenser area that was a part of the pilot study is now split off as a separate phase of the investigation, to be completed prior to the Pilot • Study and supply additional information to Fund staff. Data from the investigation will then be used to support the funding for the Pilot Study. This phasing does not constitute a change in the scope of work, to investigate and remediate soil and groundwater as necessary. Had the scope of work changed, that action would have resulted in another technical review for pre-approval per the Letter. • Furthermore, the Regional Water Quality Control Board is currently the lead agency for directing and approving all regulatory and technical aspects of the USTs case. All Regional Board staff K, E. LoRai ScC, P.E.,Gw I P�E"C. GR P.E.,SCEE,oa3umvE GR ER 11 ata Sun Cn GrM MO.Rancho Cardo CA 8WM I w .G Wbearda.oa.acWoeRvalrallq • RGGN[lG0 MPGR