SITE INFORMATION AND CORRESPONDENCE

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Duncan Austin, Site File - 2 - 11/3/2005 Former Morton Paint Manufacturing Site Stockton, San Joaquin County fillers"and a separate 225 square foot"flammable storage' building. However, there appears to be limited records of what else existed at the Morton Plant Property and no records of what was removed and what remains. 2. The Investigation Work Plan does not include adequate background information on the Morton Plant Property and Morton Operable Unit site history, including but not limited to a description of all previous waste handling practices, site investigations and tabulated data summaries of data results of analytical sampling. 3. The Investigation Work Plan states, "As presented in this Workplan,the Site will also be referred to as the Morton-Alco OU." This does not appear to be the appropriate designation. The Site subject to the work plan is more accurately call the"Morton Plant Property,"because the work only concerns property that comprised the historical boundaries of the Morton facility. The Morton Plant Property is a 1.2 acre piece of the "Morton-Alco Operable Unit", created by the Redevelopment Agency,which is a total of 2.61 acres. The Morton Plant Property is no longer a distinct parcel but a portion of Redevelopment Agency Project Area 2A as defined in the 13 September 2000 Environmental Master Plan. The Regional Board established the operable units for the Redevelopment Agency Project Area 2A to facilitate environmental cleanup at a site where there existed distinct responsible parties for different areas within Parcel 2A. By agreement with the Redevelopment Agency, three operable units were defined, none of which is a"Morton-Alco Operable Unit" as that term is used in the Workplan. The defined boundaries of the agreed-to "Morton Operable Unit", is as follows: From the middle line of the former Main Street right-of-way down to the southern boundary of `Parcel 2A' and from the midline of the former Harrison Street right-of-way east to the Lincoln Street right-of way. For the purposes of the Polanco Act, there may be a need for specific site boundaries,but for the purposes of cleanup under the Water Code, the "site" includes the discharge of pollutants within and from the property boundaries of the former Morton Paint manufacturing facility and wherever those pollutants have been discharged to. 4. The Investigation Work Plan states, " The Morton-Alco OU encompasses an area approximately one acre, located along the southern border of the Unocal OU and occupies approximately the northern two-thirds of the block bounded Main Lincoln, Market, and Harrison Streets,"This descriptive language leaves unanswered the questions of what is intended with regards to performing necessary investigations and possible remediation of the entire site(see definition of"site", above). 5. The Work Plan, Section 1.1 entitled"Site History and Description", contains a narrative description of tank and associated piping locations and should be revised to include a current map showing either an area of investigation or the location of the surveyed lot that is referenced in the footnote to the description.