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r ENVIRON MENTAL HEALTH IEPARTMENT pU1N ° c SAN JOAQUIN COUNTY s y Program Coordinators N." .� Donna K. Heran, R.E.H.S. Director 304 East Weber Avenue,Third Floor Carl Borgman, R.E.H.S. Laurie A. Cotulla, R.E.H.S. Stockton,California 95202-2708 Mike Huggins, R.E.H.S., R.D.I. cq�iko'aN�P Assistant Director Telephone:(209)468-3420 Margaret Lagorio, R.E.H.S. Robert McClellon, R.E.H.S. Fax: (209)464-0138 .Teff Carruesco, R.E.H.S. Website:www.sjgov.org/ehd/ Kasey Foley,R.E.H.S. A R AND M E GLOVER AUG 2 9 2006 FAYETTE MANUFACTURING CORPORATION P O BOX 61 TRACY CA 95378 RE: Fayette Manufacturing Corporation 7675 Eleventh Street Tracy, California San Joaquin County Environmental Health Department (EHD) has received and reviewed Risk Assessment for the Fayette Manufacturing Site (RA) dated 06 March 2006, prepared by your consultant ATC Associates, Inc. (ATC) for the above referenced site. In addition, the EHD has reviewed groundwater monitoring data acquired 26 January 2006. The conclusion presented in the RA was that there are no significant risks to human health concerns by direct exposure to residual contamination on the site. It was also concluded that the potential for vapor intrusion was not likely to occur as the site is paved with asphalt. On 19 July 2006, the EHD met with representatives of the Central Valley Regional Water Quality Control Board (CVRWQCB) to present your site for closure consideration. The CVRWQCB representatives were concerned with the recent increase of contaminant concentrations in monitoring wells MW2 and MW-3. The CVRWQCB representatives also noted that no remediation attempts had been conducted to reduce the concentrations of contaminants in the source area. The CVRWQCB was not in favor of closure consideration at this time. Further review of the RA lead the EHD to a determination that the site data had not been correctly applied to the risk analyses. ATC applied soil analytical data acquired on 05 April 2004 to the San Francisco Bay Regional Water Quality Control Board's (SFBRWQCB) Environmental Screening Levels (ESLs)for deep soil (more than 3 meters in depth) and in the Johnson Ettinger Soil Gas Model. There are several problems with the use of only this data and the deep soil model: • With the possible exception of the CPT-1 sample, the soil samples acquired on or about 05 April 2006 were collected well outside the source area previously shown to be significantly impacted by petroleum hydrocarbons quantified as gasoline (TPH-g) or diesel (TPH-d) or by benzene, toluene, ethylbenzene, and total xylenes (BTEX). • The CPT1-S25 data, while collected nearer to the area of known significant impact to soil, was collected at a depth (25 feet below surface grade), which had been previously shown to not be impacted even in the most intensely impacted area (See Table 1 of Problem Assessment Report (PAR) dated 07 November 1995; for