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Page 1 of 1 <br /> Lori Duncan [EH] <br /> From: John Lynch Dlynch@wrightenvironmentalservices.com] <br /> Sent: Saturday, October 22, 2011 3:56 PM <br /> To: Paul Verma <br /> Cc: Lori Duncan [EH]; Chris Palmer' <br /> Subject: City of Tracy Sites- Soil Vapor Issue-Cage-n-Play and Delta <br /> Paul <br /> Chris had spoken to Lori when we were reviewing the Cage-n-Play and Delta sites for the Site Closure <br /> Summaries and discussed with her the requirements and guidelines from RWQCB for No Further Action Required <br /> (NFAR)aka closure. While soil samples were collected and analyzed and groundwater from quarterly events <br /> were analyzed at.both Cage-n-Play and Delta Disposal over the history of the projects, we were never"required" <br /> to collect soil vapor data. It was Chris and my understanding that the RWQCB would not accept a paper rationale <br /> for site closure using the ESLs and wants soil vapor data to back up the site closures. That is why we prepared <br /> the soil vapor work plans. There was no information in the files that would allow Chris to recommend closure <br /> without collecting additional samples to evaluate risk of soil vapors. For that reason we then contacted you to <br /> discuss the need for Soil Vapor Work Plans, last year. Chris cannot use another rationale since we have no vapor <br /> data to back it up. This is our current understanding of the process. <br /> Right now it appears this "site closure" process Will only get stricter with the updated ESLs that are supposed to <br /> be coming'out next year. ESL numbers for vapor are projected to decline and the TPH soil and water numbers <br /> may as well. If people are in buildings and residual TPH in soil/water are present on any site then the data needs <br /> to be collected. Chris pointed out to Lori that we never.discussed soil vapor during the site investigations but that <br /> is a RWQCB decision and the tiered local enforcement agencies like County EHD have to go along. Hence the <br /> soil vapor work plans. <br /> RWQCB can change/amend the"site closure" requirements and soil vapor will probably drive all closures in the <br /> future at all sites in the State in our opinion. <br /> As soon as we can get a purchase order or.PSA in place to implement.the.Soil Vapor Work Plans, and <br /> resume Quarterly Monitoring at Boyd we will resume work on the sites. Lou has recovered and or <br /> recreated our budgets for this work that we lost with our accounting system crash(s). I will send the <br /> budgets by email as I am still working out of town M-F on a diesel spill that is just about completely <br /> finished. <br /> John <br /> 209-603-3394 <br /> 10/24/2011 <br />