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San Joaquin County <br /> Environmental Health Department DIRECTOR <br /> Donna Heran, REHS <br /> 600 East Main Street <br /> N; PROGRAM COORDINATORS <br /> Q'la <br /> < Stockton, California 95202-3029 PRobert McClellon,REHS <br /> • Jeff Carruesco,RENS,RDI <br /> Website: www.sjgov.org/ehd Kasey Foley,REHS <br /> i4 VZ' <br /> Phone: (209)468-3420 <br /> Fax: (209) 464-0138 <br /> March 3, 2010 <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 Department (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 Sacramento County): <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 evaluation 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 authoritative guidance documents, such as <br /> those provided by the California Department of Toxic Substances Control (DTSC) or by the Los <br /> Angeles Regional Water Quality Control Board (LARWQCB). The EHD requested technical data <br /> supporting the subdivision of total petroleum hydrocarbons quantified as gasoline (TPHg) data <br /> into smaller carbon number ranges than reported by the 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 conducting 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 samples for total petroleum hydrocarbons <br /> quantified as diesel (TPHd) by method TO-17 as was approved in the work plan and has not <br /> provided a justification for deviating from the work plan 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 />