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California Regional Water Quality Control Board <br /> vCentral Valley Region <br /> Robert Schneider Chair <br /> .Alan C.Lloyd Ph.D. Arnold Schwarzenegger <br /> Secretary for Sacramento Main Office <br /> Environmental Intemet Address: http://www.waterbouds.c&gov/wntralvalley Governor <br /> Protection 11020 Sun Center Drive#200 Rancho Cordova,CA 956766114 <br /> Phone(916)464.3291 Fax(916)464-4797 n IEC2; n nIEU <br /> ,_-� <br /> 4 November 2005 NOV — 9 2005 <br /> Mr. Steve Pinkerton ENVIRONMENT HEALTH <br /> City of Stockton, Department of Housing & Redevelopment PERMIT/SERVICES <br /> 305 North El Dorado Street, Suite 200 <br /> Stockton, CA 95202 <br /> 0 VERSIGHT A GREEMENT FOR REMEDIAL ACTIONS AT FORMER MORTON PAINT <br /> MANUFACTURING SITE,STOCKTONSOUTHSHORE REDEVELOPMENTAREA 2A, SAN <br /> JOAQUIN COUNTY <br /> The Stockton Redevelopment Agency and the Regional Water Quality Control Board, Central Valley <br /> Region (Water Board) have been developing an agreement, pursuant to the Polanco Redevelopment Act, <br /> whereby the Water Board would oversee remedial actions undertaken by the Redevelopment Agency at <br /> the former Morton Paint Manufacturing Site (Morton-Alco Site). Water Board staff s need to review <br /> available information about this site and its relationship to adjacent sites has led to some delays in <br /> finalizing this agreement. This site is complicated due to the fact it is part of a larger site, Parcel 2A of <br /> the South Shore Redevelopment Area, and the environmental pollution is related to issues at the other <br /> Redevelopment Agency sites on Parcel 2A, particularly the L&M and Unocal sites. Parcel 2A involves <br /> multiple responsible parties, and is subject to multiple settlement agreements, finalized over the last year <br /> or so, that are relevant to the Morton-Alco Site. In addition,the Water Board recently received, on 20 <br /> October 2005, the Redevelopment Agency's Comprehensive Cleanup Strategy Parcel 2A and adjacent <br /> areas which includes the Morton Paint Manufacturing Site. <br /> The Water Board remains committed to complete an Agreement with the Redevelopment Agency for the <br /> investigation and remediation of the Former Morton Paint Site. Attached is the Agreement with several <br /> proposed revisions that would address the Water Board's remaining concerns. Also attached is a revised <br /> Scope of Work as Exhibit C, including a proposed time schedule, to replace Exhibit C and D. <br /> I am providing you with the following comments in order to clarify the proposed revisions to the <br /> Agreement: <br /> 1. The scope of work to be performed under the agreement, as proposed by the Redevelopment <br /> Agency, did not constitute a full investigation and cleanup, as required by applicable law, it <br /> only provided the first step in an iterative process. I am concerned that as drafted that <br /> agreement would suggest that completion of the proposed scope of work would be sufficient <br /> and would result in immunity to the Redevelopment Agency prior to all necessary work being <br /> completed. The attached draft agreement incorporates revisions that would address this <br /> California Environmental Protection Agency <br /> �d Recycled Paper <br />