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Site Closure Request
<br /> Pombo Property June 14,2005
<br /> �... with concentrations of TPHd remaining in the groundwater in accordance with and in compliance with
<br /> SWRCB resolutions.
<br /> Residual petroleum hydrocarbons at the Pombo Property are at least 40 years old and groundwater at the
<br /> site is virtually non-detect for BTEX and PAH compounds. The data provided in previous investigations
<br /> and the updated HHSE indicate that with no further regulatory action,the residual hydrocarbons will
<br /> remain localized and continue to attenuate naturally over time.
<br /> Residual concentrations of hydrocarbons will not unreasonably affect the existing or probable future
<br /> beneficial uses of groundwater because of the absence of existing wells in close proximity to the affected
<br /> groundwater. Furthermore,the poor quality of shallow groundwater in the Tracy area is prohibited for
<br /> use as domestic or municipal supply in accordance with the City of Tracy Municipal Code
<br /> (Section 11.1.16), for administrative reasons unrelated to presence of residual crude or fuel oils.
<br /> Therefore,groundwater at the Pombo Property in its present condition is not considered to be an
<br /> environmental concern.
<br /> Residual petroleum hydrocarbons remaining in the soil at the Pombo Property does not pose a threat to
<br /> those in the vicinity according to the results of the updated HHSE(Geomatrix,2001),considering limited
<br /> routes to the impacted soil and the improbability of TPHc to mobilize and current land use zoning.
<br /> Residual petroleum hydrocarbons will not pose a threat to current or probable future beneficial land uses
<br /> and will not pose a threat to public health and safety.
<br /> SAIC has been unable to locate documentation on a land use covenant for the Pomba Property as
<br /> suggested by the DTSC. CEMC is currently working with the City of Tracy regarding land use and
<br /> zoning restrictions to ensure the Pombo Property meets the recommendations set by the DTSC on future
<br /> land use. The current property use, including the fire station,is zoned as"general highway commercial"
<br /> and does not pose a health risk based on the results of the HHSE. Therefore,no further corrective action
<br /> is necessary and regulatory closure of this site is appropriate.
<br /> Based upon our evaluation of previous investigations,the updated HHSE and current land use zoning,this
<br /> site conforms to the all of the RWQCB's criteria to be classified and closed as a low risk site and that site
<br /> closure would comply with State Resolutions. Therefore, SAIC on behalf of CEMC,requests a letter of
<br /> "No Further Action"be issued for the Pombo Property by the RWQCB.
<br /> 6. REFERENCES
<br /> City of Tracy,December 2004,"City of Tracy Municipal Code,Title 10,Article 19-Planning and
<br /> Zoning,General Highway Commercial Zone",http://ordlink.com/codes/tracy/Ordinance Code
<br /> 1069,December 2004.
<br /> ,May 2005,"Official City of Tracy Zoning Map",May 20,2005.
<br /> DTSC,August 2002,"Review of the October 4,2001 Results of the Updated Human Health Screening
<br /> Risk Evaluation, Pombo Property(report)and the May 9,2002 Response to Comments January
<br /> 2, 2002 letter(letter),Pombo Property",August 5,2002.
<br /> Earth System Consultants,Inc.,August 1999,"Chevron Right-Of-Way Relocation Preliminary
<br /> Assessment Soil Sampling, 1755 West 1 I`h Street,Tracy California",August 24, 1999.
<br /> Geomatrix Consultants,Inc.,January 2000,"Soil and Groundwater Investigation Report and Human
<br /> Health Screening Evaluation,Pombo Property,(San Joaquin County APN 232-170-07), 1755
<br /> West 11 th Street,Tracy, California",January 17,2000.
<br /> .,December 2000,"Report of Additional Soil and Groundwater Investigation,Pombo Property,
<br /> (San Joaquin County APN 232-170-07), 1755 West 11`h Street,Tracy, California", December 21,
<br /> 2000.
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