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San Joaquin County <br /> En *ronmental Health Department vi <br /> DIRECTOR <br /> Donna Heran,REHS <br /> 1868 East Hazelton Avenue <br /> California 3 PROGRAM COORDINATORS <br /> *`. Robert McOellon,REHS <br /> Jeff c rrue c a,REHS,RDI <br /> • , <br /> Kasey Foley,RHS <br /> � Linda Turtte,REHS <br /> Phoma. (209)468-3420 Rodney Estrada,REH; <br /> Fax: (209) 4-0138 Adrienne Eft ser,ISIS <br /> March 3 , 2014 <br /> Chevron Products Company 3panos Jet tenter <br /> Darryl Pessfer !Marc W. Hardy <br /> 145 S. State€college010rvTrintity Parkway, "' floor <br /> Brea, to 92321 Stockton, to 95219 <br /> United States Dept of the Army San Joaquin County <br /> Corp of Engineers Stockton Metropolitan Airport <br /> Gerald Vincent Patrick tarreno <br /> C S K - 5000 S. Airport Way, <br /> 325 J Street Room 202 <br /> Sacramento, CA 95314 Stockton, CA 95206 <br /> Subject* Stockton Metropolitan Airport <br /> Former Fuel Station <br /> 5000 South it o Boulevard <br /> Stockton, CA 96206 <br /> The Sari Joaquin County Environmental Health Department ( H has reviewed Human <br /> Reamer Risk Assessment (HHRA) and Rearrest for Closure Report (Report) dated June 3, <br /> 2012, submitted on your behalf by l arnage Environmental, Inc., (Marriage), 1n the Report, <br /> Ramage presented the H RA for the petroleum hydrocarbons originating from the former <br /> UST"s at the site and requested the site be considered for low-risk closure. The EHD had <br /> reviewed the report and responded by letter, dated October 30, 2912 with recommendations. <br /> Ramage submitted Groundwater Monitoring storing e ort Second Half 2013 (GWR), dated <br /> December 39, 2913, that addressed some of the EHD recommendations.. <br /> By email dated March 4, 2014, Ramage adage requested the FIND to specify the information needed <br /> to complete the case closure evaluation for this site. In the email; Ramage indicated that the <br /> HHRA evaluated the risk associated with on-site ingestion and dermal contact with surface <br /> soil, on-site inhalation of outdoor air, and off--site ingestion and dermal contact with <br /> groundwater. The evaluation was based only on post-2992 soil samples, excluding all older <br /> data as not representative due to contaminant degradation,thereby effectively considering the <br /> data "non- detectable". In addition, the HH A included contaminant concentration, but not an <br /> estimate of time required data to reach Water Quality Objectives tr i . The following <br /> actions should be taken to resolve some of the identified issues and to move the site toward <br /> closure- <br /> The HHRA should be reevaluated using all soil data, including fare-2092 data to determine <br /> a conservative, worse-case scenario to pelt an upper limit on the risk. A reasonable <br /> degradation rate may be utilized to "correct" data for use in the HHRA, <br />