SITE INFORMATION AND CORRESPONDENCE

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Steve Pinkerton -2 - 4 November 2005 Former Morton Paint Co. Site concern. The tasks outlined in the Exhibit C regarding soil and groundwater investigation and cleanup are standard tasks that are necessary at a site to accomplish cleanup. Some may require a greater effort than others depending on the extent of contamination of the site. Staff understands that the Redevelopment Agency does not know whether the 10 underground storage tanks at the site (9 of which contained hazardous substances and 1 containing gasoline),were removed. The proposed scope of work involved the implementation of a work plan to dig a 100-foot-long exploratory trench at the site. The work plan was unclear as to when and what subsequent actions will be performed depending on the results of the trenching. Exploratory trenching could be useful in determining whether the tanks remain and whether site soils are contaminated there from. Therefore, staff agrees that exploratory trenching should be a part of the scope of work under the agreement. In order to facilitate its finalization, Attachment 2 to this letter presents staff s comments on the exploratory trenching work plan. The work plan should be revised and resubmitted to the Water Board for approval within 30 days from the date of this letter so that work may proceed. The work plan should include an implementation schedule. 2. The Scope of Work,to be included as Exhibit C to the Agreement, should follow the Water Board's usual steps in the scope of work for site remediation activities. Proposed Exhibit C now includes: a. The identification of data gaps for soil and groundwater pollution and an investigative work plan to fill those data gaps; b. Preparation of a site assessment report in conjunction with a feasibility study/remedial options evaluation which evaluates the potential remedial alternatives for the soil and groundwater pollution at the site, additional investigation may be necessary as an iterative process; c. A draft Cleanup Plan proposing a preferred remedial alternative for addressing contaminated soil and cleaning up polluted groundwater, emanating from the site; d. Presentation of the proposed plan to the public for comment, and e. Based on public comment,preparation of a final Cleanup Plan for consideration by the Water Board, subject to the requirements of the California Environmental Quality Act, f. Implementation of the Cleanup Plan,including obtaining the necessary discharge or other permits, g. Preparation of a Cleanup Plan Implementation Report. Attachment 3 to this letter presents a new Exhibit C to the Agreement. 3. There has apparently been a misunderstanding regarding the description of the property to be covered by the Agreement. I now understand that you will be preparing a metes and bounds description and when complete, appropriate modifications to the Agreement will be made. The Regional Board understands that the Redevelopment Agency will also address pollution that has migrated to off site areas. Section 1.4 of the Agreement has been modified to clarify this understanding (see Attachment 1, redline/strikeout language in Section 1.4).