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Mr Daniel K Barber, P E <br /> ' September 9, 2003 <br /> Page 5 of 17 <br /> ' REGULATORY STATUS <br /> The lead regulatory agency for the site is San Joaquin San Joaquin County Public Health <br /> ' Services — Environmental Health Division (SJCEHD), which has assigned it Case No 1927 <br /> The County acts as a Local Oversight Program (LOP) to the California Regional Water <br /> ' Quality Control Board — Central Valley Region 5 (RWQCB), providing oversight until such <br /> time as case closure is warranted The RWQCB Case Number is 390212 The case has also <br /> been listed on the State Water Resource Control Board's (SWRCB) on-line "GeoTracker" <br /> database (petroleum release sites) and has been assigned the Global ID T067700147 <br /> ■ In a "Notice of Responsibility" letter dated April 25, 1997, the SJCEHD notified Western <br /> Oil & Spreading that the site could not be considered for closure until further site <br /> investigation or remedial action was completed Mr Jeffrey Wong, the current SJCPHS <br /> ' case officer for the site, has been actively providing oversight and communication with <br /> Western Oil & Spreading at least since 1998, when the first of a series of letters were sent <br /> ' to the company requesting investigations to evaluate the extent of residual hydrocarbon <br /> contamination left after the 1987 underground fuel storage tank removals <br /> REGULATORY CONSIDERATIONS <br /> r <br /> Sail Contamination <br /> In a recent telephone conversation with Mr Jeffrey Wong of SJCPHS, he communicated his <br /> concerned about not having the extent of the plume defined by non-detection data points and <br /> his potential concern about the residual hydrocarbons in soil eventually impacting <br /> groundwater and raising soluble concentrations above current levels (Wong, 2003) Mr <br /> ' Wong also requested an effective conceptual model for the soil TPH distribution at the site <br /> Although there are no direct Appropriate, Relevant and Applicable Regulations (ARARs) <br /> ' published for hydrocarbons in soils, various California RWQCBs have used a Designated <br /> Level Methodology (DLM)--or Risk-Based Screening Levels (RBSLs) (California Regional <br /> ' Water Quality Control Board, 2001) However, these are only screening-level criteria <br /> guidelines, used to evaluate if additional investigation and/or remediation is warranted, and <br /> they are not utilized by the County of San Joaquin (Wong, 2003) Criteria to be considered in <br /> ' selecting the appropriate soil RBSLs include <br /> ■ Contamination is limited to surface soil (less than 10 feet sleep) or to subsurface soil <br /> ' (greater than 10 feet deep), <br /> ■ Land use is residential or commercial/industrial, and <br /> Stellar Environmental Solutions <br /> ' Z PROIECsd�Anne P'onu2oolo->)iB.hndod ClmiueRspun.nd FgureeREPORTBeEteeM93o0)Jus <br />