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. r &T <br /> • ��5 ,l1 <br /> San Joaquin County <br /> Environmental Health Department DIRECTOR <br /> Donna Heran,REHS <br /> —� 0� 600 East Main Street <br /> �},����� < Stockton, California95202-3029 PRO <br /> Stockton, <br /> REHSCOORDINATORS <br /> y; C Robert McClellon,REHS <br /> 1.19L1 Jeff Carruesco,REHS,RDI <br /> Kasey Foley,REHS <br /> Website: www.sjgov.org/ehd Linda Turkatte,REHS <br /> qc FOR' Phone: (209)468-3420 <br /> Fax: (209)464-0138 <br /> April 15, 2011 <br /> Mr. Cyrus Youssefi Ms. Sharla Hardy <br /> 601 Main Street Investors PTP City of Stockton - Public Works <br /> 1006 Fourth Street, Suite 701 425 N. EI Dorado Street <br /> Sacramento, CA 95814 Stockton, CA 95202 <br /> Subject: Main Street InvestorsNillas de Amistad L P Case <br /> #39-0515732 <br /> 39 -T0605157322 <br /> 601 E. Main Street <br /> Stockton, CA APN: 149-180-06 <br /> The San Joaquin County Environmental Health Department (EHD) has reviewed Closure <br /> Summary Report (CSR) dated January 10, 2010, submitted by Advanced GeoEnviron mental Inc. <br /> (AGE). The CSR includes a summation of the site investigation activities and a request for closure. <br /> In CSR, AGE concluded that: <br /> 1. The vertical and lateral extent of impacted soil was adequately delineated; <br /> 2. The groundwater was not significantly impacted based on the grab groundwater analytical <br /> results from the boring B3 sample, situated down-gradient of the former underground <br /> storage tank (UST) pit; <br /> 3. The concentrations of total petroleum hydrocarbons (TPH) locally exceeded the San <br /> Francisco Bay Regional Water Quality Control Board (SFBRWQCB), Environmental <br /> Screening Levels (ESLs), but the potential problem was minimized by the depth of <br /> occurrence of impacted soil and the concrete sidewalk covering the impacted soil; and <br /> 4. There is a low potential for a potential vapor intrusion problem due to the depth of <br /> occurrence of impacted soil, the fine-grained character of the soil, and the barrier provided <br /> by the overlying concrete sidewalk. <br /> The EHD concurs with the second conclusion, but a few issues require additional information for <br /> the EHD to concur with the first, third and fourth conclusions and with the recommendation for site <br /> closure. The EHD notes that the LIST pit excavation is very near a residential apartment building <br /> that has a basement, so the issue of a potential vapor intrusion problem must be carefully <br /> evaluated to protect the health of the residents of the building. Normally, heating oil, the primary <br /> contaminant of concern, poses less of a concern in regard to vapor intrusion issues compared to <br /> more volatile hydrocarbons such as gasoline, and indeed the soil analytical data available shows a <br /> low volatile hydrocarbon content. The EHD concerns arise from the following circumstances: <br /> 1. No data has been presented to show that impacted soil does not extent north of the tank <br /> pit excavation toward the residential building and its basement; and <br /> 2. Final disposition of the free-product-impacted soil, segregated as the 'hot pile' during <br /> excavation, is not clear, and it appears that this intensely impacted soil may have been <br /> returned to the excavation. <br /> CSR Comment Letter 0411 <br />