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o�rN San Joaquin County U trllc <br /> r <br /> Environmental Health Department oR <br /> C E <br /> ?•' ' '.o Donna Heran,REHS <br /> • •G <br /> { 600 East Main Street ASSISTANT DIRECTOR <br /> Stockton, California 95202-3029 Laurie Cotulla,REHS <br /> — PROGRAM COORD/NATORS <br /> c 'P Carl Borgrnan,REHS <br /> i;6 Website: WWW-S/gov.orgdehd Mike Huggins,REHS,RDI <br /> Phone: (209)468-3420 Margaret Lagorio,REHS <br /> Fax: (209) 464-0138 Robert MCClellon,REHS <br /> Jeff Carruesco,REHS,RDI <br /> JERRY MOORE Kasey Foley,REHS <br /> MOORS PETROLEUM <br /> 885 PORTOF:INO DR JUN 2 5 2007 <br /> BRENTWOOD CA .94513-6539 <br /> RE: Moore Petroleum Bulk Plant <br /> 5491 F Street <br /> Banta CA 95304 <br /> The San Joaquin County Environmental Health Department (EHD) has received <br /> and reviewed Soil Vapor Survey Workplan (WP) dated 10 May 2007, prepared <br /> by Apex Envirotech, Inc. (AEI) on your behalf. <br /> In WP, AEI proposes to advance 13 soil vapor survey <br /> Points _ <br /> and off-site <br /> locations to collect soil vapor samples for laboratory analys saAEI proposes to <br /> drive the sampling points to a depth of three feet below surface grade (bsg) and <br /> to collect the samples into Tedlar bags after purging 3 casing volumes of soil gas <br /> and monitoring the pumped soil gas with a PID to select the time of maximum <br /> contaminant concentrations. The soil gas samples are proposed to be collected <br /> utilizing the "whole-air active approach", which the EHD is not familiar with. <br /> The EHD cannot approve the work plan as proposed for the following reasons: <br /> Department of Toxic Substances Control (DTSC) and other agencies <br /> recommend a minimum sampling depth of 5 feet below surface grade <br /> (bsg) to minimize the effects of barometric pumping; <br /> A detailed description of the probes, means Of emplacement, air pump <br /> and pumping rate was not provided; and <br /> The analytical regimen for the soil gas samples should include 1 2- <br /> dichloroethane and ethylenedibromide. <br /> The DTSC guidance document, Interim Final Guidance for the Evaluation and <br /> Mitigation of Subsurface Vapor Intrusion to Indoor Air, 15 December 2004, states <br /> that purging and sampling flow rates should be less than 200 milliliters per <br /> minute. <br /> Submit a revised work plan addressing the points noted above to the EHD by 03 <br /> September 2007. The DTSC guidance document or other authoritative guidance <br /> document should be referred to in the revised work plan. As these are guidance <br />