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Ms. Elena Reyes, City Manager January 10, 2017 <br /> City of Manteca Page 3 of 3 <br /> Former Police Firing Range <br /> The EHD is concerned with the identification and delineation of soil impacted at low concentrations <br /> of lead exceeding the cleanup goal of 80 mg/kg that was not addressed in the SREW, as noted in the <br /> EHD letter of 03 March 2016. Geocon, based on prior experience, utilized an XRF reading of 50 <br /> mg/kg as the breakpoint for soil to be excavated or left in place. However, without a demonstrable <br /> correlation between XRF and total lead data, the EHD requires that the confirmation sampling density <br /> outside the excavated area be one sample per 25-foot by 25-foot square immediately adjacent to the <br /> excavation area and one sample per 50-foot by 50-foot square over the remainder of the firing range <br /> area included in the legal description. The EHD will consider the cleanup goal achieved if the total <br /> lead data also demonstrates that soil exceeding 80 mg/kg total lead and the other COPC RSLs has <br /> been removed. In addition, because of the uncertainty associated with the screening samples in and <br /> around the berm areas, the EHD does not recommend using this soil as backfill for the finished <br /> excavation. Should this soil be used as backfill, sufficient total lead analytical data showing <br /> compliance with the appropriate RSLs must be demonstrated before being utilized as backfill in the <br /> excavation. <br /> The EHD approves the SREW with the condition that the modifications required by the EHD, as noted <br /> above, are fully implemented with the proposed actions. The EHD notes that all characterization, <br /> handling, treatment and disposal of soil potentially impacted by the metals of concern addressed by <br /> this investigation and cleanup must comply with all relevant provisions of Title 22 California Code of <br /> Regulations and Title 40 Code of Federal Regulations. <br /> The EHD will issue a certificate of completion pursuant to California Health and Safety Code Section <br /> 101480(e) upon demonstration that all cleanup goals established to protect human health for the <br /> proposed land use have been met, assuming no other environmental concerns are discovered during <br /> the course of this cleanup action. Please be advised that a certificate of completion issued by the <br /> EHD under the voluntary program only covers the scope of work as noted in the Local Voluntary <br /> Cleanup Program Remedial Action Agreement and does not constitute a 'closure" or "no further <br /> action" designation under any other authority or program, or on behalf of any other agency. Comments <br /> and questions regarding this letter should be directed to Nuel Henderson at (209) 468-3436 or by <br /> email at nhenderson(vDsicehd.com. <br /> Sincerely, / <br /> Nuel C. Henderson, Jr., PG <br /> Engineering Geologist <br /> CC: Nabaz Saieed, TY Lin Inc., 2010 Crow Canyon PI., Ste. 350, San Ramon, CA 94583 <br /> Richard Day, Geocon Consultants, Inc., 6671 Brisa St., Livermore, CA 94550-2505 <br /> Gregory Dickinson, Pacific Edge, 26431 Crown Valley Parkway, Ste 270, Mission Viejo, CA <br /> Leona Winner, DTSC, 8800 Cal Center Dr., Sacramento, CA 95826 <br /> Steven Meeks, CVRWQCB, 11020 Sun Center Dr., Ste 200, Rancho Cordova, CA 95670 <br /> (All distributed by email) <br />