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s. I � n Page 1 of 3 <br /> Mike Infurna [EH] <br /> From: Mike Infurna [EH] <br /> Sent: Thursday, July 16, 2009 8:05 AM <br /> To: 'rmarty@advgeoenv.com' <br /> Subject: RE:Vanco Site,Charter Way <br /> James Barton, on behalf of his bosses stated y sterday that the CVRWQCB would <br /> not accept soil data that exceeds ESL levels for vapor intrusion evaluations. <br /> The EHD has sent a letter out to the RP stating this and will require the approved <br /> work plan to gather, analyze, and evaluate soil vapor samples against the <br /> SFBWQCB ESLs to be enacted. A permit has :)een issued to AGE. Please confirm <br /> the start date. <br /> AGE has been sent a copy of the letter. <br /> From: Robert Marty [mailto:rmarty@advgeoenv.com] <br /> Sent: Wednesday, July 15, 2009 5:33 PM <br /> To: Mike Infurna [EH] <br /> Cc: Tim '; wlittle@advgeoenv.com; 'David Atwater' <br /> Subject: Vanco Site, Charter Way <br /> Mike: <br /> In reference to your email of 13 July 2008 (copied below), we have the following comments: <br /> It appears that the primary concern of Mr. Barton(and presumably Mr. Henderson) is for"future <br /> worker safety"when or if the site is ever"redevelop d". For this site-to be redeveloped, we can <br /> assume that the underground storage tanks (USTs) a d tank system would have to be removed. <br /> We can also assume that the UST and UST system ould be removed under some kind of permit <br /> from the County or State. And, in accordance with existing regulations (which I highly doubt <br /> will be relaxed in the future especially in our regulation-happy State of California), any workers <br /> involved in the performance of the removal of the U Ts and associated system would have to be <br /> HAZWOPER-trained. <br /> After removal of the UST system, we could presume that some State/Local agency(les)would <br /> require remediation of any significantly-impacted sol 1 encountered. And, can't we assume that the <br /> remediation would most likely be under the directior of some agency? Therefore, the chance of <br /> worker exposure—prior to redevelopment—is not an issue. Without the removal of the UST <br /> system, there is nearly no chance of redevelopment. Worker exposure during redevelopment <br /> would be "mitigated"by existing requirements for H AZWOPER training. <br /> Finally, I think you would agree that a requirement by the City Building Department for"removal <br /> of soil" is also moot; since Environmental Health and the Regional Board presently have <br /> jurisdiction (generally) over UST-related remediation in Stockton, by the time any redevelopment <br /> plans made it to the City (in anything but a conceptual form), the issue should have been <br /> appropriately dealt with by other agencies. If not, th one could presume that the other agencies <br /> (Environmental Health or Regional Board) determined that the soil was not an issue for <br /> redevelopment. <br /> 1/27/2010 <br />