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JUN/14/2006/WED 01:51 PM COS ITSG & REDEV FAX Ni, 20993750°° P. 004 Ms. Kitty Walker - 3 -. 7 June 2006 investigation Work Plan General Comments The Investigation Work Plan contains as an addendum a copy of the RDA's Voluntary Cleanup Agreement (VCA) with the Department of Toxic Substances Control (DTSC) in the matter of "Stockton WorkNet Project, 40 Lincoln Street." The Water Boards and the DTSC have a Memorandum of Understanding and a VCA is not a city or area-wide blanket agreement. As determined by the State agencies, the Central Valley Water Board is the lead regulatory agency for cleanup oversight of Project Areas 3, 4, 24 and the pollution associated with the railroad corridor. The Investigation Work Plan cites a2 September 2004 Preliminary Endangerment Assessment conducted by the DTSC for Project Area 4 and states, "DTSC stated that the level of Pb [lead] is not restrictive under a commercial office or construction worker scriario." That DTSC determination applies to lead at Project Area 4, only. No PEA has been conducted for Project Areas 3 and 24. The RDA also needs to provide the rationale for . removing the Stockton Children's Museum site from the investigation for Project Area 24. The Investigation Work Plan reports that the RDA collected five soil samples from Project Area 3 and had a forensic evaluation conducted to establish that the "hydrocarbons present in the samples could be the result of a release that occurred twenty or more years ago." The RDA needs to clearly explain its intent for the forensic evaluation. The tables and the figures in the Investigation Work Plan do not appear to correlate with regard to the sampling points and the major artifacts and the grid dimensions in the tables are rectangular while those in the figures appear square. In order to accurately evaluate the proposed sampling points within the Investigation Work Plan, the RDA needs to plot the WorkNet building, its parking areas, the railroad corridor and the abandoned street easements for Main and Market Streets, on appropriate tables and figures including Tables 3 and 4 and Figures 4 and 5. It has already been demonstrated that soil and groundwater pollution exist in the preferential pathway that is the ballast and drainpipe beneath the railroad corridor. The RDA needs to . remediate this pollution. The best use of resources would allow for the immediate removal of the source of the pollution, so that ongoing releases cease. The Central Valley Water Board letter dated 19 April 2005, Review of Investigation Report, in-part said, "Based on the results of the investigative activities at the site, petroleum contamination remains in the subsurface and the lateral and vertical extent of the pollution has not been defined." Central Valley Water Board staff in the Spills, Leaks, investigations, and Cleanup (SLIC) Program is currently working to include and update SLIC sites in the Geotracker database, which has been required of the RDA since 1 January 2005. The RDA should submit survey data for the site and all boring and well locations and now begin submitting electronic data into Geotracker. The Geotracker identification number for this site is SL0807727524 and your