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Mr. Mark Buller -2 . 17 September 2014 <br /> Idealease Stockton <br /> concentrations of 610 mg/kg in the floor sample (six feet bgs) and 3,300 mg/kg in the <br /> eastern sidewall sample (four feet bgs). The excavation near the drain clean out and <br /> drain pipe (Area B) contained maximum TPHd concentrations of 560 mg/kg in the floor <br /> sample (eight feet bgs) and 13,000 mg/kg in the southern sidewall sample (four feet <br /> bgs). <br /> 3. Concentrations in the sidewall samples from the excavations indicate the remaining <br /> mass of TPHd in soil above the ESL is undefined (sidewall at Area B contained <br /> 13,000 mg/kg of TPHd). It is unclear why the maximum concentration detected at the <br /> Site was in a sidewall sample or why the excavation did not proceed and remove this <br /> mass. By 14 November 2014, Idealease needs to prepare and.submit a work plan to <br /> delineate the remaining mass of TPHd in Site soil. The delineation of the remaining <br /> mass in soil is required prior to assessment for closure in accordance with the LTCP. <br /> 4. Central Valley Water Board staff may request that a deed covenant be filed for the area <br /> of remaining soil concentrations that pose a potential threat to human health. Idealease <br /> may choose to excavate the remaining soil mass and close the Site with unrestricted use <br /> (no deed covenant). Idealease may submit a work plan to excavate remaining soil mass <br /> in lieu of a work plan for delineation. However, the extent of TPHd in soil that exceeds <br /> the ESLs will need to be delineated either through an investigation or through <br /> confirmation samples after additional excavation. <br /> 5. Effective 13 October 2014, Central Valley Water Board will no longer accept hard copy <br /> submittals. Idealease needs to continue to submit electronic documents to GeoTracker <br /> by the deadline. If you need additional assistance with GeoTracker you may call the <br /> help desk at (916) 341-5791 or log on to the State Water Board's GeoTracker website at <br /> http://geotracker.waterboards.ca.gov ,, and click on the Electronic submittal of <br /> information. <br /> In summary, Central Valley Water Board staff does not concur that the Site meets the criteria for <br /> unrestricted use in accordance with the LTCP. Remaining soil concentrations exceed the ESLs <br /> for gross contamination and may pose a risk to onsite construction workers. Board staff may <br /> request that a deed covenant be filed in order to close the unauthorized release case for the <br /> Site with remaining concentrations that exceed the ESL for TPHd remaining in place; however, <br /> Idealease needs to delineate the mass of soil remaining at the Site. By 14 November 2014, <br /> Idealease needs to submit either a work plan to delineate the extent of TPHd in soil or a work <br /> plan to excavate the TPHd that exceeds the ESL for TPHd at the Site. In addition, Idealease <br /> should submit future reports electronically to GeoTracker and cease submittal of hard copy <br /> reports. <br /> If you have any questions, you may contact me by phone at(916)464-4819 or email me at <br /> kshelton waterboards.ca. ov. <br /> KRISTI SHELTON, P.E. JOSEPH E. MELLO, CHG 545 <br /> Water Resources Control Engineer Chief, Storage Tank Enforcement Unit 1 <br /> Aboveground Tanks Cleanup Unit <br /> cc: San Joaquin County Environmental Health Division, Stockton <br /> Mr. Brian Millman, Advanced GeoEnvironmental, Stockton <br />