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Mr. Steve Johnson <br /> July 1, 2005 <br /> Page 2 <br /> collected from areas that have not been impacted by agricultural or industrial <br /> chemicals. If other properties in the area have gone through similar site <br /> investigations, it may be possible to use data from these sites for establishing <br /> background metal' concentrations providing that soil types are compatible. This <br /> may only be done in consultation with the DTSC Project Manager. <br /> • The HERD memorandum indicates that Appendix B (Health and Safety Plan) <br /> should be reviewed by a DTSC IHSS professional. DTSC IHSS can review the <br /> Health and Safety Plan if requested. However, employers are responsible for <br /> providing a safe and healthy workplace, and for complying with applicable <br /> regulations. <br /> Please note that the Workplan prepared by MACTEC was not signed by either a <br /> California Professional Geologist or Professional Engineer as required by State statute <br /> and regulation. DTSC views the primary intent of the submitted report was to constitute <br /> a comprehensive Risk Assessment Workpian and that the supplemental site <br /> assessment was to support the RA. However, the supplemental site assessment <br /> should be reviewed, conducted and reported under either a California Professional <br /> Geologist or Professional Engineer as appropriate. <br /> A letter from the San Joaquin County Environmental Health Department (SJCEHD) <br /> dated May 5, 2005 provided information regarding groundwater impacts associated with <br /> the Site. Based on the May 5, 2005 letter, it appears that continued monitoring and <br /> additional investigation will be required by SJCEHD prior to Site "Closure" under their <br /> oversight. DTSC understands that American Forest Products Company (AFPC) is the <br /> responsible party for the former underground storage tanks and groundwater releases. <br /> However, the chemicals of concern being monitored in association with the <br /> groundwater impacts need to be addressed within the RA. Specifically, the sources to <br /> groundwater should be determined to establish they are not a health risk. Including the <br /> potential source of tetrachloroethene (PCE), that is undetermined. Additionally, a figure <br /> showing the groundwater monitoring well locations needs to be included to help <br /> establish contaminant source and impact areas. <br /> Again, in the professional opinion of MACTEC, "No Further Action" areas may mean <br /> that no further assessment work is needed, if the appropriate analytical data (data <br /> which meets the data quality objectives) is available. However, those areas still need to <br /> be addressed to the satisfaction of DTSC HERD. if you should have any questions <br />