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California R*ional Water Quality &ntrol Board <br /> Central Valley Region t . <br /> Terry Tamminen Robert Schneider,Chair <br /> Secretaryfor Arnold Schwarzenegger <br /> 3443 Routier Road,Suite A,Sacramento,Caliromia 95827-3003 /� <br /> Environmental (916)255-3000•Fax(916)255-3015 E`_�E#n „�GoDvernor <br /> Protection http://www.swrcb.ca.gov/mgcb5 LLL��� VILr�7i <br /> FEB 2 B 2004 <br /> ENVIRONMENT HEALTH <br /> February 20, 2004 PERMIT/SERVICES <br /> Randtron <br /> C/O Clifton J. McFarland <br /> Attorney at Law <br /> Gibson, Dunn & Crutcher, LLP <br /> 333 South Grand Avenue <br /> Los Angeles, CA 90071-3197 <br /> Dear Mr. McFarland: <br /> DRAFT REMEDIAL INVESTIGATION REPORT, LODI SOUTH AREA, SAN <br /> JOAQUIN COUNTY <br /> The Regional Water Quality Control Board (Regional Board) has received TRC's report entitled <br /> "Draft Remedial Investigation Report, Lodi South Area", dated November 2003. Regional <br /> Board staff has reviewed the report and our comments are provided below. <br /> General Comments <br /> 1. Data Gaps at the Site: <br /> The report is well written and provides a good summary of the remedial investigation <br /> work performed at the site. We appreciate the level of effort that has gone into the <br /> investigation of the solvent contamination in the soil and groundwater at Lodi South <br /> Area. However, a small, but important, amount of additional investigation is needed in <br /> order for the Regional Board to concur that remedial investigation of the Lodi South Area <br /> is complete. The remaining data gaps are as follows: <br /> a) Downgradient Extent of Contamination is Undefined: <br /> The potentiometric map of the August 11, 2003 water levels (Figure 6, copy attached) <br /> clearly shows a significant easterly component to the predominantly southern <br /> groundwater flow direction. Based on earlier groundwater levels taken in February <br /> 2003, which indicated that the groundwater flow was directly south, wells SA-10 and <br /> SA-17 were installed. However, as Figure 6 makes clear, additional monitoring wells <br /> are needed to the southeast of the fairly large and most highly contaminated area <br /> California Environmental Protection Agency <br /> n Recvcled PaDer <br />