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I <br /> PUBLIC EALTH SER CES <br /> Qu�N <br /> SAN JOAQUIN COUNTY <br /> ENVIRONMENTAL HEALTH DIVISION N j <br /> Ernest M. Fujimoto, M.D., M.P.H., Acting Health Officer - <br /> 304 E.Weber Ave., 3rd Floor • P. O. Box 388 a Stockton, CA 95201-038$ �4........ , �P <br /> 209/468-3420 �lFORa <br /> 5 <br /> DOUG WESTERHAVEN Ic <br /> AMERICAN FOREST PRODUCTS <br /> 4000 KRUSE WAY PL BLDG 2 STE 120 MAILED AUG 2 81995 <br /> LAKE OSWEGO OR 97035 i <br /> RE: American Moulding and Millwork (AFPC) SITE CODE: 1882 <br /> 2801 West Lane <br /> Stockton CA 95208 <br /> San Joaquin County Public Health Services, Environmental Health Division (PHS/EHD) has reviewed the July <br /> 1995 Report entitled Evaluation of Hydrocarbon Mobility .prepared by Dames and Moore for the above <br /> referenced site. i <br /> The report provides an introduction which states the purpose and organization of the report, describes the <br /> work performed between May 1 and May 26, 1995,summarizes the site history, describes field and laboratory <br /> procedures, tabulates the results, draws conclusions and provides recommendations based on site specific <br /> conditions and the designated level methodology. <br /> . i <br /> in the report Dames and Moore chooses to calculate the designated level evaluation using different <br /> environmental attenuation factors for different analytes. The PHS/EHD interpretation of the designated level <br /> methodology is that the environmental attenuation factor is based on site conditions and not on the specific <br /> contaminant. An attenuation factor of 500 for TPH-d and 100 for other contaminants is an incorrect use of <br /> the environmental attenuation factor. The absorptive properties of the contaminant is factored in to the <br /> equation using the leachability factor. <br /> The designated level methodology states that a 100 fold attenuation factor should be used in a disposal <br /> situation which provides an average degree of protection for water quality from discharge of wastes under <br /> reasonable worst-case conditions. An average site would be a landfill in the alluvium of the Central Valley <br /> with a significant depth (>30 feet) of soil containing appreciable and continuous clay or silty-clay strata <br /> between the base of the landfill and ground water. For sites that provide less than this "average" amount of <br /> water quality protection ie sandy'soii or high groundwater an attenuation factor of 1 or 10 should be chosen. <br /> PHS/EHD has determined an attenuation factor of 10 for this site consisting of sandy soil lenses separating silty <br /> clay lenses and less than 30 feet to groundwater (DMW-5 at 26 feet bgs with 10 year seasonal high <br /> groundwater at 35 feet) is an appropriate attenuation factor for this site. The site specific total designated level <br /> for diesel at this site is calculated by multiplying the Water Quality Goal (.1ppm)x Environmental Attenuation <br /> Factor (10) x Leachability Factor (368 I/mg) — 368 mg/kg. The reported concentration of Diesel in DMW-5 <br /> at 26 feet bgs is 1900 mg/kg. Therefore the reported concentration exceeds the total designated level and does <br /> not provide adequate water quality protection. <br /> PHS/EHD has determined that levels of Carbon Tetrachloride and 3,2 dichloroethane 'in DMW-5 exceed <br /> Maximum Contaminant Levels for these two constituents in drinking water. Chlorinated hydrocarbons were <br /> not detected by laboratory analysis of soil samples from boring DMW-5. This indicates that the,source of the <br /> leak has not been discovered. The report states that Kearney-KPF located at 1624 E. Alpine may be an offsite <br /> source. <br /> A Division of San Joaquin County Health Care Services <br />