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KLEINFELDER ' On September 23 1997, the RWQCB issued "Revised Waste Discharge Requirements for Spreckels Development Company, Former Spreckels Manteca Sugar Plant, Lime Pond Closure, San Joaquin County." The Revised Waste Discharge Requirements Order No. 97-204 (hereinafter "WDRs") detailed the requirements the RWQCB had on the property owner, including but not limited to a required Workplan for Evaluation ' Monitoring of Groundwater for the waste water ponds. In response to the RWQCB requirements, Kleinfelder was hired by Spreckels ' Development Company to develop the December 23, 1997 "Evaluation Monitoring Work Plan, former Spreckels Sugar Plant No. 2...." That work plan was reviewed by the CVRWQCB, which issued a letter dated October 30, 1998. That letter stated that ' the proposed wells; "screens should be not greater than 10 feet... should be set at a depth that intercepts the contaminant plume or is at the expected depth of the plume at the well's location. That depth should be determined by hydrologic modeling before ' drilling, Hydropunch data, or other means." Based on later discussions with Mr. Rosenbaum, the Hydropunch methodology was refined. On April 2, 1999, Kleinfelder abandoned monitoring well MW-6, due to constraints of the residential development. The well was later relocated just outside of the residential area ' in the future planter area in the northwest corner of the former Spreckels site. A total of 3 wells (MW-25, MW-26 and MW-27) and one relocated well (MW-6r) were installed between March 2, 1999 and March 29, 1999 in the northwestern portion of the subject site (Plate 2). Although the total depth of the wells were each approximately 50 feet bgs, the borings were advanced to total depths ranging from 50 to 85 feet bgs. Soil ' samples were continuously logged in borings MW-6r and MW-25 from the surface to depths of 55 and 85 feet bgs., respectively. Soil samples from boring MW-26 were continuously logged from 22 to 85 feet below ground surface (bgs). Soil samples from ' boring MW-27 were continuously logged from 25 to 50 feet bgs. A total of 41 discrete Hydropunch® groundwater samples were collected from the four new monitoring wells MW-6r and MW-25 through MW-26. The groundwater samples were collected from first t encountered groundwater (approximately 20 feet bgs.) and every five feet or change in lithology thereafter to the total depth of the borings. The discrete groundwater samples were field screened for assessment of the proposed screened interval of each well. ' The results of the abandonment of MW-6 and the installation of MW-6r, MW-25, MW- 26, and MW-27 were detailed in a report dated May 30, 2000 titled, "Additional Groundwater Assessment, Lime Pond Area, Former Spreckels Sugar Plant No. 2, ' 18800 South Spreckels Road, Manteca, California, (WDR Order # 97-204)." That report included the following conclusions and recommendations: ' 1) Groundwater flow direction was found to be generally towards the northwest at an approximate gradient of 0.0020 ft./ft. ' 2) Based on the field-test kit groundwater sampling results conducted during installation of four newer monitoring wells MW-6r, MW-25, MW-26, and MW-27, a discrete interval of relatively elevated chemical constituents were noted at a general depth ranging from 40 to 50 feet below ground surface. 20-3978-03.MN7/ST08R117 February 1,2008 ©2008 Kleinfelder ' Page 8 of 19