SITE INFORMATION AND CORRESPONDENCE_FILE 2

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F ENVIR01', MENTAL H ALTRA)EPARTMENT +N SAN JOAQU N COUNTY Donna K. Heran, R.E.H.S. Program Coordinators 304 East Weber Av nue,Third Floor Carl Bman, R.E.H.S. Director ar g ` - Laurie A. Cotulla,R.E.H.S. Stockton,Califor iia 95202-2708 Mike Huggins, R.E.H.S., R.D.I. Assistant Director Telephone: (2 9)468_3420 Margaret Lagorio, KE ES. QQF0 Robert McClellon, R.E.H.S. Fax: (209) 64-0138 Jeff Carruesco, R.E.H.S. Website:www.,,jgov.org/ehd/ Kasey Foley, R.E.H.S. IIC WILLIAM BERGVALL SEAR 0 8 2007 FORMER AMERICAN FOREST PRODUCT 2801 WEST LANE STOCKTON CA MCD LAZARES STOCKTON LLC 634 N. SANTA CRUZ AVE. STE 100 LOS GATOS, CA 95030 RE: FORMER AMERICAN FOREST PRODUCT 2801 WEST LANE STOCKTON CA. San Joaquin County Environmental Health Department (EHD) has reviewed No Further Action Request (NFAR) dated February 16, 2006, 2005 Groundwater Monitoring Report (2005 Report) dated August 2006, Draft Work Plan for Additional 1.2-DCA Investigation . in the Vicinity of DMW-9 (DWP) dated December 18, 2006, and previous reports and site data for the above referenced site. The NFAR, prepared by URS Corporation ( RS), includes the results of field investigations carried out in July and September of 2005 to delineate the extent of the contaminant of concern, 1,2-dichloroethane (1,2-OCA). URS's conclusions presented in the NFAR were: • Data from the monitoring event demonstrate a decreasing trend in 1,2-DCA concentrations, and • The dissolved 1,2-DCA plume has been adequately delineated. On April 12, 2006, EHD discussed the NFAR with the Central Valley Regional Water Quality Control Board (CVRWQCB). The CV WQCB concurred with the EHD's conclusion that the report did not provide adequate information to evaluate the closure request. Among the deficiencies were: • Historical data tables were not provided to c,upport the data in the graphs used to plot the complete concentration trends of ,2-DCA in DMW-2, DMW-5, DMW-6 and DMW-9 (Figures 3 and 4). The only cata provided were for the year 2005, as shown on a site map (Figure 2). • In the graph for DMW-9 (Figure 4), two dat points were termed as "outliers" and were omitted from the trend analysis resulting in a downward trend of 1,2-DCA. Results from previous quarterly monitoring reports (QMRs) were not included to in the graph and no technical justificatia was provided to exclude the two "outliers".