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California Regional Water Quality Control Board <br /> Central Valley Region <br /> Robert Schneider,Chair x <br /> Winston H.Hickox Gray Davis <br /> Secretaryfor Sacramento Main Office Governor <br /> Environmental Internet Address: htt3://www.swrcb.ca.gov/rwgcb5 <br /> Protection 3443 Routier Road,Suite A,Sacramento,California 95827-3003 <br /> Phone(916)255-3000•FAX(916)255-3015 <br /> ////����OvCAD <br /> 5 December 2002 FNl I DeC 0 9 Zpp2 <br /> PERM T/SFR��FS TN <br /> Mr. Brian Miller <br /> Agrium <br /> 1220 Potter Drive <br /> West Lafayette, IN 47906 <br /> REVIEW OF RESPONSE TO COMMENTS,WESTERN FARM SERVICE, <br /> STOCKTON, SAN JOAQUIN COUNTY <br /> We have reviewed the 11 November 2002 Response to Your Letter Dated 22 August, 2002 <br /> Regarding Review of Reports (Response) submitted by Sierra-Pacific Group on behalf of <br /> Western Farm Service (WFS) for the former PureGro agricultural chemical facility at 1905 North <br /> Broadway Avenue in Stockton. The Response responds to comments in the Office of <br /> Environmental Health Hazard Assessment (OEHHA) 31 July 2002 letter and disagrees with <br /> Board staff's suggestion of working with the Department of Toxic Substances Control for further <br /> health risk assessment evaluation and public participation guidance. <br /> Based on discussions with OEHHA staff and a review of information in the June 1999 Draft <br /> Human Health Risk Assessment and Risk-Based Cleanup Level Development Report and the July <br /> 2000 Response to Comments Draft Human Health Risk Assessment and Risk-Based Cleanup <br /> Level Development Report,by 17 January 2003,please provide the following: <br /> • A list of cleanup goals protective of the probabilistic 95th percentile health risk for <br /> an on-site residential child for soil and groundwater; <br /> • A list of cleanup goals using the deterministic approach protective of the one in a <br /> million cancer risk for an on-site residential child for soil; <br /> • Evaluation of health risk from chemical volatilization of groundwater constituents <br /> into indoor air pathways for both on and off site structures; <br /> • A table of groundwater elevation data as depth below ground surface (bgs) as <br /> opposed to mean sea level; and <br /> • A new table of soil analytical data that references depth from ground surface and is <br /> organized by area, then by the following depth intervals: 0-3 feet bgs, 3-15 feet bgs, <br /> and 15-70 feet bgs. <br /> California Environmental Protection Agency <br /> fie?Recycled Paper <br /> The energy challenge facing California is real. Every Californian needs to take immediate action to reduce energy consumption. <br /> For a list of simple ways you can reduce demand and cut your energy costs,see our Web-site at http://www.swrcb.ca.gov/mgcb5 <br />