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CORRESPONDENCE_2019
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Last modified
1/19/2024 3:12:51 PM
Creation date
5/20/2022 11:54:33 AM
Metadata
Fields
Template:
EHD - Public
ProgramCode
4400 - Solid Waste Program
File Section
CORRESPONDENCE
FileName_PostFix
2019
RECORD_ID
PR0504201
PE
4430
FACILITY_ID
FA0000214
FACILITY_NAME
PILKINGTON NORTH AMERICA INC PLANT 10
STREET_NUMBER
500
Direction
E
STREET_NAME
LOUISE
STREET_TYPE
AVE
City
LATHROP
Zip
95330-9739
CURRENT_STATUS
01
SITE_LOCATION
500 E LOUISE AVE
P_LOCATION
07
P_DISTRICT
003
QC Status
Approved
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Brusca File No. 137-002 <br /> <br />Page 3 <br />December 2, 2019 <br />Murphy Parkway Property Soil Gas Monitoring <br /> <br /> <br />SOIL GAS LABORATORY TESTING <br /> <br />The soil gas samples collected from soil gas monitoring wells SGMW1 and SGMW2 were <br />transported to a State-certified laboratory for analysis. Both soil gas samples were analyzed for <br />methane, oxygen, carbon dioxide, and nitrogen by ASTM Method D1946. The samples also <br />were analyzed for VOCs by EPA Test Method TO-15. The analytical laboratory results are <br />summarized on the attached Table I, along with data from past monitoring. The laboratory <br />reports, internal laboratory QA/QC data, and chain-of-custody documentation also are attached. <br /> <br /> <br />RESULTS AND DISCUSSION <br /> <br />As shown on Table I, the November 2019 soil gas samples collected from SGMW1 and SGMW2 <br />did not contain methane at a concentration above the laboratory reporting limits of 0.00024% <br />and 0.00025% for these samples, respectively. Methane concern at the site is not indicated by <br />November 2019 data. <br /> <br />The soil gas samples collected from monitoring wells SGMW1 and SGMW2 in November 2019 <br />contained chloroform at concentrations above the laboratory reporting limits. The SGMW1 <br />sample also contained a low concentration of toluene. To evaluate the significance of the <br />concentrations of these VOCs detected in the soil gas samples (p articularly w ith respect to the <br />potential for vapor intrusion into indoor air spaces at concentrations that could be considered a <br />human health concern), we have considered Regional Screening Levels (RSLs) published by the <br />US Environmental Protection Agency (USEPA) and Environmental Screening Levels (ESLs) <br />published by the San Francisco Bay Regional Water Quality Control Board (SFBRWQCB). The <br />applicable screening values for chloroform and toluene are shown on Table I along with the <br />analytical data from the soil gas monitoring well s. The published RSL values are for indoor air <br />VOC concentrations. For use in the screening evaluation for the subject site, the indoor air RS L <br />values have been adjusted by an attenuation factor of 0.03 to simulate the attenuation that could <br />occur from soil gas to the indoor air environment. <br /> <br />As shown on Table I, the concentration of toluene det ected in the November 2019 soil gas sample <br />SGMW1 and the concentration of chloroform detected in sample SGMW2 do not exceed the listed <br />commercial/industrial agency screening values considered and, as such, are not considered a <br />concern. The soil gas sample collected from SGMW1 contained 190 ug/m3 chloroform which <br />exceeds the screening level considered (18 ug/m3). The source of the chloroform detected in the <br />SGMW1 sample is unknown. Chloroform occurs naturally in certain settings, although <br />anthropogenic sources are responsible for much of the chloroform in the environment. A <br />common anthropogenic source of chloroform in the environment is the discharge of chlorinated <br />drinking water. It is possible that the detected chloroform in soil gas at the SGMW1 location is <br />attributable to landscape irrigation in the area of SGMW1 utilizing municipal water. <br />Nonetheless, it is our opinion that the elevated concentration of chloroform detected at the <br />SGMW1 location would not represent an unacceptable vapor intrusion health risk at the onsite <br />warehouse building, due to the distance to the building and the nature of floor slab system <br />associated with the building. As mentioned above, the soil gas screening levels considered were <br />developed using an attenuation factor of 0.03, which most certainly is excessively conservative <br />considering that the floor slab for the onsite warehouse building is seven inches thick and is
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