SITE INFORMATION AND CORRESPONDENCE_FILE 2

Home Browse Search

Y San Joaquin County DIRECTOR Environmental Health Department Donna Heran,REHS A SSISTANT DIRECTOR 2: � 2 600 East Main Street Laurie Cotulla, REHS W: :� Stockton, California 95202-3029 PROGRAM COORDINATORS • Mike Huggins,REHS, RDI • � Margaret Lagorio, REHS Cq<<FOR�j\P Website: www.sjgov.org/ehd RobertMcClellon, REHS Phone: (209) 468-3420 .teff Carruesco, REHS, RDI Fax: (209) 464-0138 Kasey Foley, REHS 07 May 2009 George W. Lockwood, P.E. Chief, UST Cleanup Unit Division of Water Quality State Water Resources Control Board PO Box 2231 Sacramento, CA 95812 Subject: Response to Russell Chapin Petition dated 17 February 2009 The San Joaquin County Environmental Health Department (EHD) has reviewed the Petition for Case Closure of Underground Storage Tank Site, 1766 Monte Diablo Avenue, Stockton, San Joaquin County (the 2009 Petition), dated 17 February 2009, and by this letter is responding to the petition in accordance with your letter of 20 April 2009. The EHD has reviewed the 2009 Petition and finds it quite similar to his earlier petition dated 23 November 2004 (the 2004 Petition). The EHD responded by letter dated 25 January 2005, to the technical issues raised in the 2004 Petition and to Mr. Chapin's concerns regarding the handling of his case by the EHD, now available on GeoTracker, titled Response to Petition for Case Closure Review 01-25-2005. Also now on GeoTracker are the EHD technical responses to the site closure requests by Mr. Chapin's consultant, ATC; the closure requests were dated 10 August 2004 and 23 November 2004, the EHD responses were dated 04 October 2004 and 07 January 2005. All of the EHD technical responses noted above to Mr. Chapin's closure request and the 2004 Petition focus on the technical issues pertaining to his site, the various models, and on the interpretations and predictions presented by his consultants. In the EHD directive letter of 03 March 2005, the EHD provided a list of technical issues that needed to be addressed for an EHD concurrence with a closure request. To date, neither the technical issues raised about the ATC models nor the items that the EHD noted should be addressed for closure consideration have been provided to the EHD. The technical deficiencies of the ATC models upon which the closure requests were based will not be reiterated here, but the items the EHD noted as needed for an EHD closure request concurrence are listed: • A demonstration of plume stability and degradation; • A reasonable estimate of the time required for the impacted groundwater to return to background conditions; • A reasonable estimate of the residual contaminant mass in soil and groundwater 2009 Appeal Response 0509