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JUL-26-2004 09:02 - 4WQCB-CV - 916 255 3052 P.03i05 <br /> duL <br /> Peter Wallace -2- <br /> Claim No. 1714 <br /> Discussion <br /> In your letter, you state that the investigative work approved by SJCEHD was aimed at <br /> determining the extent of Stoddard solvent contamination, and not to determine the'extent of the <br /> chlorinated solvent contamination at your site. I respectfully disagree. The SJCEHD has <br /> consistently directed you to analyze for chlorinated solvent contamination in all environmental <br /> samples collected from your site'since December 6, 1996. The collection of this laboratory data <br /> required a separate laboratory analysis to be performed (USEPA Method 601/8260). I must:Cord <br /> that,after December 6, 1996,the objective for the investigation at your site was to determine both <br /> the magnitude and extent of the chlorinated solvent contamination as well as the Stoddard I <br /> solvent contamination at your site. f <br /> C <br /> You also state that the data collected from the site strongly indicates that two separate but N <br /> partially commingled plumes exist. According to your letter, the Stoddard solvent plume is <br /> primarily on-site,in the area of the former USTs, and the chlorinated solvent is primarily offsite. <br /> Again, I must respectfully disagree. My review of the quarterly monitoring reports for your site <br /> found that significant concentrations of chlorinated solvents have been identified onsite as well <br /> as offsite of your property. Furthermore, my review found that the extent of delineated <br /> groundwater contamination is practically identical for both the Stoddard solvent and the <br /> chlorinated solvent contamination. <br /> In your letter,you disagree with the conclusion of the FMD that any additional investigation of <br /> the extent of Stoddard solvent contamination will be incidental to the investigation of the extent <br /> of chlorinated solvents at your site and that remediation of the Stoddard solvent contamination, if <br /> required,will be addressed during remediation of the chlorinated solvents. I tend to agree with <br /> the FMD. My review found that by September 2002, the downgradient extent of Stoddard i <br /> solvent contamination in the groundwater had been delineated.but the extent of the chlorinated <br /> solvents(PCE and TCL)had notbeen delineated. In addition, I note that the relative p <br /> concentrations of the chlorinated solvent contamination throughout most of the groundwater j <br /> plume were higher than concentrations of Stoddard solvent contamination. Finally,while there <br /> is no drinking water standard (MCL) established for Stoddard solvent by the California <br /> Department of Health Services, the MCLS for the chlorinated solvent contaminants identified at <br /> your site have been established, and at very low levels: 5 ppb for PCE/TCE, 6 ppb for cis-1,2- <br /> DCA and 0.5ppb for vinyl chloride. So, I must agree with the Fund Manager that the chlorinated <br /> solvent contamination at your site,not the Stoddard solvent contamination, will primarily drive <br /> any additional investigation and ultimately, the cleanup required at your site. <br /> Notwithstanding the above,I disagree with the FMD in that at least some of the near-term <br /> investigation and monitoring activities at the site will be aimed at both Stoddard solvent and the <br /> chlorinated solvents. <br /> Ca6lornia Enviroomenta/Protection Agency <br /> e�RecydMPaper ' <br /> I <br /> t <br />