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EDMUND G. BROWN JR. <br />GOVERNOR <br />0* LironN IA . <br />Water Boards <br />MATTHEW RODRIQUEZ <br />SECRETARY FOR <br />ENVIRONMENTAL PROTECTION <br />Central Valley Regional Water Quality Control Board <br />5 May 2017 <br />Bill Doerr Robin Stafford <br />The Newark Group Morrison & Foerster LLP <br />33878 Drifting Sands Circle 425 Market Street <br />Thousand Palms, CA 92276 <br />San Francisco, CA 94105 <br />NEWARK GROUP INC. CASE #2, 800 W. CHURCH STREET, STOCKTON, <br />SAN JOAQUIN COUNTY, CASE# 391188 <br />Central Valley Regional Water Quality Control Board (Central Valley Water Board) staff <br />reviewed the Work Plan — Area B-7 Additional Delineation of Petroleum Hydrocarbon Extent <br />and Additional Assessment for Shallow Soil (Work Plan) dated 5 April 2017, submitted on your <br />behalf by Amec Foster Wheeler PLC (AFW) for the Newark Group Inc. Case #2 property <br />located at 800 West Church Street in Stockton (Site). <br />AFW submitted the Work Plan in response to the Central Valley Water Board letter dated <br />18 November 2016, as well as the outcome of a 26 January 2017 meeting between Central <br />Valley Water Board staff, Mr. Bill Doer of Caraustar Industries Inc., and Mr. Gary Lieberman of <br />AFW. In the Work Plan, AFW proposes to advance a total of eight (8) direct-push borings as <br />follows: <br />Borings Purpose <br />Proposed <br />Depth <br />(ft bgs) <br />Soil Sampling <br />Depth <br />(ft bgs) <br />GW Sampling <br />Analysis Depth <br />(ft bgs) Analysis <br />DP-5 thru <br />DP-8 <br />Delineation of extent of <br />TPHd in groundwater 65 none none 25, 45, <br />55, 65 TPHd <br />DP-9 thru <br />DP 12 <br />LTCP Direct Contact <br />and Outdoor Air <br />Exposure evaluation <br />10 between 0-5, <br />between 5-10 <br />TPHg, TPHd, <br />BTEX, MTBE, <br />naphthalene <br />none none <br />=TPHdtotal petroleum hydrocarbons as these!, TPHg=TPH as gasoline; BTEX=benzene, toluene, ethylbenzene, and xylenes; <br />MTBE=methyl tert butyl ether; ft bgs=feet below ground surface; LTCP=Low Threat Underground Storage Tank Case Closure <br />Policy <br />Central Valley Water Board staff concur with the scope of work proposed in the Work Plan with <br />the following comments: <br />1. AFW proposes to analyze collected groundwater samples only for TPHd. While the <br />purpose of borings DP-5 through DP-8 is to delineate the extent of TPHd in <br />groundwater, AFW detected TPH as gasoline (TPHg) in borings B-7, B-39, and B-41 in <br />the B-7 Area. As such, please also analyze collected groundwater samples for TPHg. <br />KARL E. LONOLEY ScD, P.E., CHAIR I PAMELA C. CREECON P.E., SCEE, EXECUTIVE OFFICER <br />11020 Sun Center Drive #200, Rancho Cordova, CA 95570 www.waterboards.ca.gov/oentralvalley <br />CS RECYCLED PAPER