SITE INFORMATION AND CORRESPONDENCE

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JUN/14/2006/WED 01:51 PM COS FSG & REDEV FAX N. 20993750QQ P. 005 Ms. Kitty Walker - 4 - 7 June 2006 consultant may obtain information about the electronic submittal of data at the State Board website: http://www.waterboards.ca.gov/ust/cleanup/electronic_reporting/faq.html. The cover letter to the Investigation Work Plan states, "The other key piece in moving this project forward is the execution of an oversight agreement." We have a typical Water Board oversight agreement already in-place, which covers this site, see Attachment 6. It is our intent to recover costs for regulatory oversight work conducted at this site under the Cost Recovery Program, as acknowledged by your staff person in the attachment. Cleanup Guidelines . The Polanco Redevelopment Act, California Health and Safety Code, Section 33459.1, states that the RDA "shall request cleanup guidelines from the department [DTSC) or the California regional water quality control board before laking action to remedy 01 remove a release:: The , State Water Board and the nine Regional Water Boards derive their statutory authority from Porter-Cologne, which is codified in Division 7 of the California Water Code (CWC). Thus, the CWC provides guidance. In addition, the Fourth Edition of the Water Quality Control Plan for the Sacramento River and San Joaquin River Basins (hereafter Basin Plan) designates beneficialuses of the waters of the State, establishes water quality objectives (WQ0s), to protect these uses, and establishes implementation policies to attain WQ0s. The beneficial uses of the groundwater beneath the site are domestic, municipal, industrial, and agricultural supply. Also, the groundwater at the site is likely periodically hydraulically connected to the Stockton Channel, a surface water body that is within the designated boundary of the Sacramento-San Joaquin Delta. For additional broad cleanup guidelines the Central Valley Water Board also refers the RDA to 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 is also necessary and will. be provided by written comment on data and work plans submitted by the RDA for this 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 RDA may take action to remedy or remove pollution found at the site. Central Valley Water Board staff encourages the RDA to move forward with an approved conceptual development fOr this site, and to communicate that land use to Central Valley Water Board.'" staff. Railroad Corridor and Drainpipe The Investigation Work Plan states that a French drain was discovered beneath Project Area 3. A French drain is a trench filled with crushed stone for drainage and is typically unlined or may be lined with sheeting. Work conducted at Project Area 3 uncovered a 1-foot diameter drainpipe. Ballast, which is also typically crushed stone, should be present for the entire length of the railroad corridor. Ballast can also act as a preferential pathway for pollution. II 111. I II 101M•111•11.