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Lee Higgins - 3 - 25 January 2011 <br /> Catellus Property <br /> Tracy, San Joaquin County <br /> • Shallow groundwater exceeds numerous California and Federal total dissolved solids <br /> standards for drinking water and agricultural purposes. Depth to onsite groundwater is <br /> approximately 36 to 40 feet bgs. Also, it is unlikely shallow onsite groundwater would <br /> be considered for a drinking water source and therefore the direct exposure route is <br /> incomplete. Therefore, health risks and hazards for potential residential exposure to <br /> onsite groundwater were not evaluated quantitatively. <br /> • The California Natural Diversity Database, 2009, maintained by California Department <br /> of Fish and Game, was reviewed to search for threatened, endangered, or sensitive <br /> species in the vicinity of the Site. Six threatened and endangered species sightings <br /> were listed in the vicinity of the Site. Two sightings of Swainson's hawk were noted <br /> within one mile. The property is within the sphere of influence of the 2004 City of Tracy <br /> General Plan designated "Urban Reserve 4" which indicates the area of the Site may be <br /> developed for industrial, commercial and office uses near California Interstate 205. <br /> There will be some low-density residential developments further from the highway. <br /> SAIC concluded that the future development is not likely to provide adequate habitat for <br /> the hawk or the other species noted in the vicinity. <br /> In summary, SAIC's report determined that the potential cancer risk to a potential future <br /> resident was 4E-06, which is within the range of risk management of 1 E-06 to 1 E-04. The <br /> non-cancer health hazard, at 0.003 is well below the de minimus level of 1 which is a <br /> conservative estimate of risk. This level of cancer risk and non-cancer health hazard exposure <br /> to onsite soils does not present an unacceptable risk to hypothetical future onsite residents. <br /> Based on my review, I have the following comments: <br /> • Consistent with other TAOC/OVP sites, a Soil and Groundwater Management Plan <br /> (SGMP) needs to be submitted. The SGMP designates Chevron as the responsible <br /> party and serves as a guideline for Chevron to implement for handling soil affected by <br /> the degraded crude oil that may be encountered during future Site activities. <br /> • Given that the areas of crude oil affected soil/groundwater are present within/beneath <br /> the W. Byron Road easement, UPRR tracks, active pipelines, it is unlikely drinking <br /> water wells would be installed or development allowed or completed in this utility <br /> corridor. <br /> • Central Valley Water Board staff concurs with the findings of the HHSE and related <br /> supporting documentation, and that the Site is a candidate for closure. A request for a <br /> No Further Action Required (NFAR) determination may be prepared. <br /> • Documentation to support a NFAR closure determination should be completed in <br /> accordance with California Regional Water Quality Control Board, Central Valley <br /> Region's 16 April 2004 update to Appendix A of the Tri-Regional Board Staff <br /> Recommendations for Preliminary Investigation and Evaluation of Underground Tank <br /> Sites - No Further Action Requests. Section 6.5 - NFAR for Cases Exceeding Water <br /> Quality Objectives should be followed for documenting Site conditions. <br />