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FILL uu :y <br /> 0 <br /> ENVIRONMENTAL HEALTH DEPARTMENT <br /> SAN JOAQUINilCOUNTY <br /> Unit Supervisors <br /> Donna K.Heran,R.E.H.S. <br /> 304 East Weber Avenue, Third Floor r Carl Borgman,R.E.H.S. <br /> Californias Mike Huggins,R.E.H.S.,R.D.I. <br /> Al Olsen,R.E.H.S. Stockton, Califo 1.95202-2708 Douglas W.Wilson,RT.H.S. <br /> Program Manager <br /> Telephone, (209)',468-3420 Margaret Lagorio,R.E.H.S. <br /> Laurie A.Cotulla,R.E,H.S. Fax: (209) 464-0138 Robert McClellon,R.E.H.S. <br /> Program Manager 11 Mark Barcellos,R.E.H.S. <br /> MARTIN HARRIS d s AUG 0 12002 <br /> 5151 ALMONDWOOD DRIVE <br /> MANTECA CA 95337 <br /> RE: Tuff Boy Trailers SITE CODE: 1424 <br /> 5151 Almondwood Drive <br /> Manteca CA 95337 <br /> San Joaquin County Environmental Health Department were <br /> has reviewed the <br /> "Site Closure Documents" dated June 18, 2002 that w6,re submitted on your behalf by <br /> Ground Zero Analysis, Inc. (Ground Zero) and has the following comments. <br /> Ground Zero submitted this document along with a recommendation that the site receive <br /> a designation of"No Further Action required". SJC/EHD doI not agree that this site is <br /> ready for such a designation. The groundwater contar0l,inatio'n at this site has not been <br /> vertically or laterally defined. Before a site can be considered for a low-risk closure, as <br /> Ground Zero undoubtedly knows but has recommended in previous quarterly <br /> groundwater monitoring reports, the extent of contamination proposed to be left behind <br /> must be fully defined. Groundwater at this site is currently monitored to the areas west, <br /> northwest and southwest of the source area. Areas east of the source area have never <br /> been investigated, though two quarterly groundwater monito ing reports state that the <br /> groundwater flow direction was to the east. The vertical extent of the contamination in <br /> groundwater has not been fully investigated. <br /> Several other issues are of concern. Ground Zero sub mitted calculations of the <br /> contaminant mass remaining in both soil and groundwater at this site, but gave little to <br /> no explanation of how they derived the fields in their charts. "For example, the chart of <br /> contaminant mass in soil lists each contaminant divided into three zones, but no written <br /> definition or map describing what a 'zone' constitutes iYas provided. Likewise, an <br /> explanation of how the 'average' contaminant concentrations used in the calculations <br /> were arrived at was also not provided. One cross-sectional 8iagram was submitted with <br /> the documents, but no map was provided explaining where the A-A` line was drawn, nor <br /> were there notations on the cross-section of which points were projected onto the line. <br /> In addition, Ground Zero has performed no fate and transpo,i�modeling to support their <br /> theory that this is a low risk site. <br /> A well receptor survey completed for this site lists six wells as being located within a <br /> 2000-foot radius of the site, but a map accompanying the survey shows many more <br /> residences located within this area. The water sources) forlhese residences, as well as <br /> L <br /> for the subject site, were not identified. <br /> _-J <br />