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San Joaquin Co my <br /> OA .u'N C Environmental 'Health epartment DIRECTOR <br /> Donna Heran, REHS <br /> 600 East Main Str 3et <br /> U). Stockton, California 95102-3029 PROGRAM COORDINATORS <br /> Y Robert McClellan,REHS <br /> Jeff Carruesco,REH5,RDF <br /> 0. -. gip Website: www.sigov.org/ehd Kasey Foley,REHS <br /> Phone: (209) 468-34-20 <br /> Fax: (209) 464-0138 <br /> June 22, 201 <br /> z3'' <br /> 0 <br /> Mrs. Helen Higgins <br /> 2100 Promontory Point Lane <br /> Gold River, CA 95670-7269 <br /> i <br /> Subject: Vogue Cleaners LOP Case#: 231032 <br /> 2315 N. California St. APN: 125-380-16 <br /> Stockton, CA 95204 SWRCB-CUF#: 011775 <br /> I <br /> i <br /> The San Joaquin County Environmental Health Department (EHD) has reviewed the <br /> Environmental Screening Level Assessment document dated December 4, 2009, <br /> submitted by Foothill Engineering and has the following comments. <br /> In evaluating sites for closure (no further action status) the EHD requires the responsible <br /> parties to conduct a vapor intrusion hazardous risk evaluation to determine if residual <br /> petroleum contamination in the soil and groundvvater pose a risk to human health. <br /> Commonly, to complete this requirement, soil gas samples are collected and evaluated <br /> against the San Francisco Bay Regional Water Quality Control Board (SFBRWQCB), <br /> Environmental Screening Levels (ESL). In lieu of collecting soil gas samples, responsible <br /> parties may provide technical justification that conditions at the site, such as soil and <br /> groundwater contamination, exposure path ays, building location/construction <br /> specifications, etc, do not facilitate vapor migration and/or exposure of occupants working <br /> or living in or near the building to unsafe vapor concentrations. The assessment <br /> document submitted to the EHD contains a request to waive soil gas sampling, arguing <br /> that existing site conditions do not facilitate exposure of humans to harmful vapors based <br /> on contaminant concentrations in the soil samples analyzed over time. <br /> The EHD and the Central Valley Regional Wate Quality Control Board (CVRWQCB) <br /> consider petroleum hydrocarbon impacted groundwater, as well as impacted soil, a <br /> potential source for the migration of vapor to the surface. An evaluation of groundwater <br /> as a source of vapor intrusion Was not included in the assessment. In addition, the <br /> evaluation depended on future building code requir ments to provide adequate abatement <br /> of vapor intrusion for any occupants. Deferring addressing a potential vapor migration <br /> issue to future building construction does not adequately address the concern now. The <br /> EHD notes that access limitations, due to the close proximity of buildings to the former <br /> underground storage tank (UST) pits, did not permit advancing soil boring through either <br /> former UST excavations; in fact, BH-1, a slant boring, had to be started approximately 25 <br /> feet away from the former UST #1 location. Therefore, the most impacted soil may not <br /> have been sampled and the data utilized for the Evaluation may not represent the most <br /> hazardous soil. <br />