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a <br /> San Joaquin County DIRECTOR <br /> Environmental Health Department tonna Heran,REHS <br /> 600 East Main Street <br /> ASSISTANT DIRECTOR <br /> .< Laurie Colulla,REHS <br /> Stockton, California 95202-3029 <br /> • PROGRAM COORDINATORS <br /> Margaret Lagorio,REHS <br /> Website: www.sjgov.org1ehd Robert McClellon,REHS <br /> Phone; (209)468-3420 Jeff Carruesco,REHS, RDI <br /> Fax: (209)464-0138 Kasey Foley, REHS <br /> September 28, 2009 <br /> Mr. Matt Gabris <br /> Sara Lee Bakery Group Inc. <br /> 3500 Lacey Road <br /> Downers Grove, Illinois 60515-5424 <br /> Subject: Earth Grains I formerly Kilpatrick Bakery LOP Case#: 2371 <br /> 1717 S. Center St. CUF#: 04423 <br /> Stockton, CA 95201 APN: 165-072-28 <br /> The San Joaquin County Environmental Health Department (EHD) has reviewed No <br /> Further Acton Request Report and Quarterly Ground Water Monitoring Report (Third <br /> Quarter—July 2009) (NFAR) dated August 31, 2009 submitted by your consultant, PSC. <br /> The NFAR includes historical soil and ground water data compiled from the site and also <br /> includes laboratory data for the groundwater samples collected from the eight <br /> monitoring wells for the site on July 15, 2009. <br /> The NFAR concludes that the site is adequately characterized, poses no threat to the <br /> public, and requires no further action. Included in the NFAR are discussions of the <br /> technical issues required for a site to qualify for a no further action status. The EHD has <br /> evaluated the data for the site and cannot concur with PSC conclusions for the following <br /> reasons: <br /> 1. The vertical extent of the groundwater contamination in the core area <br /> (MW-2 & MW2A) has not been demonstrated. No soil or groundwater data is <br /> available deeper than the deep monitoring well, MW-2A. This well is screened <br /> from 45 feet below ground surface to 55 feet below ground surface and has <br /> contained the highest concentration of the petroleum constituents of concern <br /> (COC). Without knowing the plume bottom (vertical extent), the residual mass <br /> estimates included in the NFAR are not likely to be correct. In addition, it is not <br /> known whether other migratory zones are present or not in this area. The lack of <br /> vertical plume definition (an incomplete characterization) and a questionable <br /> residual mass estimate disqualifies this site from being granted a no further <br /> action status. <br /> 2. The first order degradation rate presented for benzene in MW-2 appears to <br /> include more than simple contaminant degradation, dispersion, etc. Although <br /> benzene concentrations in MW-2 dropped considerably between November 2003 <br /> and November 2005, the core area was influenced by active soil vapor extraction <br /> and an examination of benzene concentrations in MW-2 after the remedial <br /> period actually shows an increasing trend of benzene in MW-2. Increasing <br /> groundwater concentrations indicate the plume is not stable. Unstable plumes <br /> disqualify a site from being granted a no further action status. <br /> 1717 Center NFAR denial CML 9-28-09 <br />