SITE INFORMATION AND CORRESPONDENCE

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Duncan Austin, Site File • - 3 - • 11/3/2005 Former Morton Paint Manufacturing Site Stockton, San Joaquin County 6. Section 1.2 of the Investigation Work Plan is titled Alco OU Settlement Provisions. The section contains a number of statements concerning a settlement between the Redevelopment Agency and other Potentially Responsible Parties. This information is not pertinent to the investigation work plan. However, there is language in this section of the Work Plan that does not reflect the entire process . for site cleanup. Site cleanup goes beyond cleaning up the soils to health based residential standards as contemplated in that section. Site cleanup must,in addition to cleaning up groundwater, cleanup soils to protect against fixture groundwater pollution. Please see the 2 November 2000 Regional Board memo entitled"Establishing Numerical Water Quality Limits for Cleanup of Groundwater which provides the procedure for establishing numerical water quality limits as groundwater cleanup goals. See also the 19 September 2000 Regional Board memo entitled"Beneficial Use Protective Water Quality Limits for Components of Petroleum Based Fuels"and the 21 November 2000 Regional Board memo entitled"Petroleum Contaminated Soil "Inert" Classification that provides guidelines for establishing remediation goals for site cleanups. Also, the Redevelopment Agency is responsible for cleaning up offsite groundwater pollution that has migrated from the Morton Plant Property and impairs or threatens to impair the designated beneficial uses of waters of the state, in a manner that is also protective of human health. Finally,this section states, "Discussions with the Regional Board have indicated issuance of a Bifurcated No Further Action(Bifurcated NFA)would meet these requirements, thereby confirming that cleanup has been achieved during this timeframe to allow site development and long term groundwater cleanup and monitoring, and any treatment system O&M to proceed." The Work Plan should clarify what requirements this sentence references. Regional Board staff could, in particular cases, allow development of a polluted site to proceed as long as the soils have been adequately remediated and so long as any construction will not impair the completion of any necessary groundwater cleanup action. 7. In implementing the required actions of the Polanco Redevelopment Act, the Redevelopment Agency is directed to request cleanup guidelines from the Regional Board and subsequently submit a remedial action plan or cleanup plan. For cleanup guidelines, Regional Board staff refers the Redevelopment Agency to Division 7 of the Water Code, the Regional Board's Water Quality Control Plan for the Sacramento River and San Joaquin River Basins, and State and Regional Board resolutions, including State Board's Resolution No. 92-49 Policies and Procedures for Investigation and Cleanup and Abatement of Discharges Under Water Code Section 13304. Site-specific guidance will be provided in the manner that is standard practice for the Regional Board,which is by written comment on data and work plans submitted by the Redevelopment Agency for a particular site. This review protocol reflects the iterative nature of environmental cleanup, as investigation proceeds, more information is available on which to make decisions. Site-specific guidelines are necessary before the Redevelopment Agency may take action to remedy or remove pollution found at the site. Of some importance to guidelines with regard to remediation at a redevelopment site is land reuse. Thus, Regional Board staff encourages the Redevelopment Agency to move forward with an approved conceptual development for its property.