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San Joaquin County <br />Environmental Health Department <br />600 East Main Street <br />Stockton, California 95202-3029 <br />Website: www.sjgov.org/ehd <br />Phone: (209) 468-3420 <br />Fax: (209) 464-0138 <br />DIRECTOR <br />Donna Heran. REHS <br />ASSISTANT DIRECTOR <br />Laurie Cotulla, REHS <br />PROGRAM COORDINATORS <br />Carl Borgman, REHS <br />Mike Huggins, REHS, RDI <br />Margaret Lagorio, REHS <br />Robert McClellon, REHS <br />Jeff Carruesco, REHS, RDI <br />Kasey Foley, REHS <br />JOSEPH & ROSANNA PANETTA APR 2 4 2007 <br />PO BOX 1072 <br />SAN RAMON CA 94583 <br />RE: Panetta Property (former UST) Site Code: RO#0727 <br />95 W. 11'" Street SWRCB-CUF#: 17963 <br />Tracy, CA. 95376 APN: 23313024 <br />WORKPLAN: Additional Site Assessment Work Plan <br />DATED: February 23, 2007 <br />PREPARED BY: Jessica Rugge, Advanced GeoEnvironmental <br />STATUS: Disapproved <br />ADEQUATE AND NECESSARY ELEMENTS OF THE WORKPLAN (Health & Safety Code (H&S) Section <br />25296.10(c)(3)1: <br />• Install four shallow (5' bgs) slant borings under the building and five shallow vertical borings <br />around the building for vapor intrusion (soil gas) ESL evaluation as required by the END for no <br />further action consideration. <br />• Collect soil vapor samples and analyze for TPHg and TPHd (8015m), VOCs and Oxygenates, and <br />BTEX, Naphthalene, MtBE, 1,2 -DCA, and EDB (82806). <br />• Submit report of findings to the END. <br />COMMENTS AND CONDITIONS: <br />• The vapor intrusion proposal is adequate on its own but the plan does not address the lack of <br />vertical and lateral delineation of either the soil or the ground water plume limits. Residual soil <br />mass remaining at the site, as well as ground water plume delineation (lateral and vertical) is <br />required along with a vapor intrusion evaluation before a no further action evaluation can be <br />made. <br />REASONS FOR DISAPPROVAL OF THE WORKPLAN iH&S Section 25296.10(c)l3)1: <br />• Mr. Panetta has suggested that the contamination at this site is the result of the release at the <br />Chevron gas station formerly located just west of this site. The EHD has explained that this <br />conclusion must be supported by data before it can be accepted. <br />• Previous remedial action (over -excavation and soil removal) have significantly reduced the <br />ground water contamination in the center of the site. Unfortunately, the digging was limited to <br />the west by the City right of way (sidewalk). The unreachable contaminated soil left under the <br />sidewalk could be leaching into the ground water in the area of MW -8. Additional soil samples are <br />needed in the sidewalk and to the west in Adams Street to determine the source of the ground <br />water contamination noted in MW -6 and MW -8. <br />• The latest ground water data for this site indicates that elevated levels of TPH as gasoline are still <br />present in MW -6 and MW -8 that do not allow the site to qualify for no further action. Additional <br />ground water investigation is needed at least at MW -8 for vertical delineation and east and west of <br />MW-8/MW-6 to laterally define the extent of the petroleum ground water plume. <br />A work plan revision that addresses these concerns is due at the EHD immediately. <br />BY Gni <br />Michael Infurna, REHS. (209) 8-3454 <br />cc: CVRWQCB — James L. Barton, Sacramento. <br />SWRCB — CUF — Mark Owens, Sacramento. <br />AGE -- J. Rugge, 837 Shaw Rd, Stockton: <br />i q electronically sent to consultant on: 4-23-2007 <br />