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} <br /> 1 /I <br /> Y <br /> San Joaquin County <br /> Environmental Health Department <br /> o c DIRECTOR <br /> 2' Donna Heran,REHS <br /> Q: ?, 600 East Main Street <br /> �: .. <br /> :` Stockton, California 95202.3029 PROGRAM COORDINATORS <br /> _ Robert McClellon, REHS <br /> _ Jeff Carruesco, REHS,RDI <br /> QL�Fo•RN Website: www.sjgov.org/ehd Kase Fofe <br /> y,REHS <br /> Phone: (209)468-3420 Linda Turkatte,REHS <br /> Fax: (209) 464-0138 <br /> April 1, 2011 <br /> Mr. Allen Fetters <br /> Ripon Farm Service Incorporated <br /> 3660 Arrowhead Court <br /> Stockton, California 95219 <br /> Subject: Ripon Farm Service Incorporated <br /> 932 South Highway 99 (Formerly 22871 South Highway 99) <br /> Ripon, California 95366 <br /> Dear Mr. Fetters: <br /> With the exception of what is normally a minor issue, the San Joaquin County Environmental <br /> Health Department (EHD) has been ready since reviewing No Further Action Request (NFAR) <br /> dated 10 November 2009, to close your underground storage tank (UST) case. At this time the <br /> vertical and lateral extent of impacted soil and groundwater has been adequately assessed, soil <br /> has been significantly remediated and the plume of impacted groundwater appears to be in <br /> decline; the problem at this time is soil gas data that can be interpreted to indicate a potential <br /> vapor intrusion health risk. <br /> Since December 2009, the EHD has been trying to resolve the problems with the risk evaluation <br /> of vapor intrusion as related to the unauthorized release from the UST system formerly on your <br /> site. The State of California has identified vapor intrusion of structures as a potential health risk <br /> that must be adequately addressed before site closure can be granted. Assuming it is shown <br /> that vapor intrusion is not a health risk on your site, the EHD is ready to close your case. <br /> The problem that the EHD has been trying to address has to do with the methodology of the soil <br /> gas collection, the analytical method utilized and the data manipulation employed to interpret <br /> the health risk posed through vapor intrusion; the samples were not collected or analyzed by the <br /> methods proposed by your consultant and approved by the EHD, and the EHD can find no <br /> authoritative guidance document that supports the data manipulation used. The exact details of <br /> the EHD concern have been stated in letters dated 03 March 2010, 02 July 2010, and <br /> 13 December 2010. Admittedly, the descriptions of the problems in these letters have been <br /> rather technical in nature; this was done to inform your consultant exactly what is needed to <br /> achieve site closure. The EHD needs the authoritative guidance document(s) to provide a <br /> standard of practice for making sound professional judgments using the available data that was <br /> obtained and interpreted in ways that are departures from our previous experiences. <br /> Letter 4-1-11 <br />