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Taber 3911 West Capitol Avenue <br /> West Sacramento, CA 95691-2116 <br /> (916) 371-1690 <br /> Since 1954 (707) 575-1568 <br /> Fax (916) 371-7265 <br /> www.taberconsultants.com <br /> December 22, 2003 <br /> San Joaquin County <br /> Environmental Health Department [ <br /> 304 E. Weber Avenue <br /> 3rd Floor, Stockton, California 95202 OEM% <br /> � <br /> � <br /> Attention: Laurie Cotulla DV-D Nr�p,�TN <br /> Site Mitigation Unit Program Manager ��y�1RflNM� R�1C�S <br /> pr�RlVI1SrS <br /> Subject: Proposed Aerially Deposited Lead Assessment <br /> Route 99/Route 120 East (Yosemite Avenue) Interchange Project <br /> Manteca, California <br /> San Joaquin County Organization of Governments (SJCOG) is undertaking <br /> a project to improve the Highway 99 / Highway 120 (Yosemite Avenue) <br /> interchange in Manteca. The project will involve widening the existing Highway <br /> 99 bridges over Highway 120 and widening the on and off ramps. <br /> The project has completed the CEQA process and is scheduled for <br /> construction in the spring. Taber Consultants has been contracted by SJCOG to <br /> perform soil sampling to determine lead concentrations in soils expected to be <br /> excavated during the construction. Details of our proposed study are presented <br /> in the enclosed copy of our Workplan (and addendum). <br /> The purpose of our project is to determine if the proposed project would <br /> create a regulated waste, not to determine if a condition subject to regulatory <br /> requirements already exists. If the project does not occur, or if the existing soil <br /> is not disturbed by the project, waste will not be generated as defined in Title <br /> 26, and mitigation would not be required regardless of the lead content. There <br /> is a theoretical possibility mitigation would be required if extreme lead <br /> concentrations indicate the soil poses an immediate threat to human health or <br /> the environment, a very unlikely event based on the history of ADL testing along <br /> Hwy 99. <br /> Because the project is on Caltrans right of way, our study will be <br /> performed with oversight by Caltrans District 10 Office of Environmental <br /> Engineering and they have approved our draft workplan. A variance for dealing <br /> with soils containing ADL has been granted to Caltrans by DTSC (copy enclosed). <br /> The variance indicates that Caltrans actions regarding ADL are subject to <br /> regulatory agency oversight at the state level by DISC and Cal-EPA. It is our <br /> Taber Consultants <br /> Engineers and Geologists <br />