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San Joaquin County <br /> Environmental Health Department DIRECTOR <br /> M Donna Heran,RENS <br /> 2: = 600 East Main Street <br /> W. Stockton, California 95202-3029 PROGRAM COORDINATORS <br /> �: : :� <br /> Robert McClellon,REHS <br /> • Jeff Carruesco,REHS,RDI <br /> o :P Website: www.s ov.or /ehd Kasey Foley, REHS <br /> gt;�oa�' 19 9 <br /> Phone: (209)468-3420 <br /> Fax: (209)464-0138 <br /> May 7, 2010 ,�&,1 <br /> Mr. Matt Gabris <br /> Sara Lee Bakery Group Inc. <br /> 3500 Lacey Road <br /> Downers Grove, Illinois 60515-5424 <br /> Subject: Earth Grains/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 CPT <br /> Site Assessment Report (Report), dated April 1, 2010, submitted by your consultant, <br /> PSC. The Report details the installation of three cone penetrometer test (CPT) push <br /> points installed on and offsite in January 2010 in response to EHD requirements listed in <br /> correspondence dated September 28, 2009, and December 8, 2009. <br /> Groundwater grab samples were collected from CPT-1, CPT-2, and CPT-3 at the 45- <br /> foot to 55-foot below ground surface ('bgs) interval and the 70' bgs to 80' bgs interval. <br /> One soil sample was collected from the bottom of each CPT push point. <br /> The EHD had originally required a monitoring well to be installed between the core area <br /> deep well, MW-2A, and the cross-gradient deep monitoring well, MW-5A. PSC had <br /> contended that the dissolved petroleum hydrocarbons present in groundwater samples <br /> from MW-5A were not from the bakery's former underground storage tank (UST) and a <br /> grab groundwater sample could confirm this. The EHD agreed that a CPT boring could <br /> be installed in this area instead of a monitoring well. The EHD conditioned the work <br /> plan approval for the CPTs by requiring the submittal of revised residual mass <br /> calculations and additional iso-concentration maps for all constituents of concern (COC) <br /> at all depths of concern that were to be included in the report of findings presented in <br /> the context of an updated site conceptual model (SCM). Neither the estimated residual <br /> mass calculations nor the iso-concentration maps were incfuded in the report. <br /> Additionally, the report was not presented in the context of an SCM. Discussions of the <br /> nature and extent of the groundwater plume and conclusions regarding the plume's core <br /> mass or movement were not included. No recommendations for continuing the <br /> investigation, discussion of the next phase of work, or plans for the sites' remediation <br /> were included. <br /> The report is incomplete and does not comply with the requirements established by the <br /> EHD. A revision is required that addresses the concerns noted above and the <br /> conditions of the work plan approval listed in EHD correspondences dated September <br /> 28, 2009 and December 8, 2009. The revision is due on Geotracker by June 15, 2010. <br /> 1717 Center CPT report CML 5-7-2010 <br />