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San Joaquin Co my <br /> Environmental Health epartment DIRECTOR <br /> Donna Heran, REHS <br /> s: v y 600 East Main Street <br /> �. %'` !'' - :a PROGRAM COORDINATORS <br /> Stockton, California 95202-3029 Robert MaClellon,RENS <br /> • Jeff Carruesco,RENS, RDI <br /> p Kasey Foley, REHS <br /> Website: www.SJgov.o g/ehd <br /> Phone: (209) 468-3420 <br /> Fax: (209) 464-0138 <br /> March 3, 201 <br /> Mr. Robert Trommer, CHG <br /> State Water Resources Control Board <br /> Division of Financial Assistance <br /> 1001 1 Street <br /> Sacramento, CA 95814 <br /> SUBJECT: COMMENTS ON CLEANUP FUND SITE CLOSURE RECOMMENDATIONS <br /> Dear Mr. Trommer: <br /> The San Joaquin County Environmental Health De artment (EHD) has received your e-mail <br /> dated February 18, 2010, requesting comments on the status of 25 sites your office <br /> recommended for closure in 2008 through June 2009. Of the 24 sites in the. San Joaquin <br /> County LOP (one of the sites listed is in SacramentoCounty): <br /> • Eleven are either in the final closure process or are about to enter it; <br /> • Seven have problems related to vapor,intrusion evaluations, are in rebound testing or <br /> awaiting additional technical evaluation; and <br /> • Six require further work such as additional monitoring, delineation or remediation. <br /> Specifically, the EHD comments are as follows: <br /> Claim No. 8431 -22871 (now 932) S. Hwy 99, Ripon <br /> Closure on this site is delayed by a vapor intrusion eve luation that encountered TPHg in soil gas <br /> at concentrations that exceeded the Tier I evaluation. Subsequent evaluation by the consultant <br /> has been by methods that are not supported by au horitative guidance documents, such as <br /> those provided by the California Department of Toxic ubstances Control (DTSC) or by the Los <br /> Angeles Regional Water Quality Control Board (LAR QCB). The EHD requested technical data <br /> supporting the subdivision of total petroleum hydroca bons quantified as gasoline (TPHg) data <br /> into smaller carbon number ranges than reported by he analytical laboratory and validation of <br /> the data manipulation methods employed by the consultant. The EHD has questions regarding <br /> the calibration methods and standards utilized for co iducting the laboratory analysis, and the <br /> EHD is concerned that the standard utilized was not appropriate for the analytical method. In <br /> addition, the consultant did not analyze the soil gas ramples for total petroleum hydrocarbons <br /> quantified as diesel (TPHd) by method TO-17 as waapproved in the work plan and has not <br /> provided a justification for deviating from the work pl n or demonstrated that the results of the <br /> analysis employed are equivalent to those that would have been obtained by TO-17. The EHD <br /> Comments on CUF Site Closure Recommendations 0310.doc <br />