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ENVIROOdENTAL HEALTAEPARTMENT SAN JOAQUIN COUNTY r ` y Donna K. Heran, R.E.H.S. Unit Supervisors y Director 304 East Weber Avenue,Third Floor Carl Borgman,R.E.H.S. Laurie A. Cotulla, R.E.H.S. Stockton,California 95202-2708 Mike Huggins, R.E.H.S., R.D.I. ` Program Manager Telephone: (209)468-3420 Douglas W. Wilson, R.E.H.S. oq 6Ko'aNMargaret Lagorio,R.E.H.S. Fax: (209) 464-0138 Robert McClellon, R.E.H.S. Website:www.sjgov.org/ehd/ .Jeff Carruesco, R.E.H.S. JUN 12 2006 GENE GABBARD JIM & SHEYLA CREEL 10335 CREEK TRAIL 640 N EL DORADO ST STOCKTON CA 95209 STOCKTON CA 95202 RE: Gabbard Property SITE CODE: 1090 640 EI Dorado Street Stockton CA 95202 On 06 June 2006, a meeting you requested was held at the San Joaquin County Environmental Health Department (EHD) office at 304 East Weber third floor, Stockton, California. Present at the meeting were Ms. Margaret Lagorio, Ms. Lori Duncan and Mr. Nuel Henderson representing the EHD, Mr. John Gabbard - the responsible party, Mr. Jim Barton of the Central Valley Regional Water Quality Control Board (CVRWQCB), Mr. John Lane of Ground Zero Analysis, Inc. (GZAI), and Mr. Pat Riddle, Esq. and Ms. Karen Collins of the Law Offices of Patrick D. Riddle, P.C. The agenda for the meeting, supplied by Mr. Lane, included the status of free product monitoring and removal from well MW-3, the status of investigation of off-site sources of PCE in groundwater, and site closure criteria. Mr. Lane reported that free product had been removed and none remained on the site, that the lateral extent of impacted groundwater had been delineated and that the tetrachloroethylene (PCE) monitored on the site was from an off-site source. Mr. Lane recommended site closure. Mr. Riddle noted that the cleanup fund had terminated future reimbursements and indicated that the site was delineated. Mr. Riddle interpreted the State Cleanup Fund comments to indicate that the site is ready for closure; Mr. Riddle further stated that there were no monies available to do any additional work. EHD noted that the consistently higher PCE concentrations in the up-gradient wells MW-7 and MW-6 and the consistent groundwater flow direction, the lack of detectable PCE in MW-3 and the PCE concentration gradient are suggestive of an off-site source for the PCE as has been interpreted by GZAI. EHD had requested that the hypothesis or model suggested by this data be tested to validate the model —which had not been done directly, but the additional monitoring data acquired over time appears to support the model. EHD had also directed that the vertical extent of impacted groundwater be completed; this has not been done. Your site occurs in an area where impacted groundwater on some sites extends to depths exceeding 100 feet below surface grade (bsg). EHD noted that if the extents of impacted groundwater could be demonstrated, the complete removal of free product demonstrated and an off-site source for the PCE could be demonstrated, and the contamination remaining on the site can be demonstrated to be of low risk to human health and the environment, then the site would be ready for closure consideration. When leaving contaminants in place, a demonstration that the mass is undergoing natural attenuation and an estimate of the time required to achieve background conditions is also needed. The closure criteria of Appendix A of the Tri-Regional Guidelines must still be satisfied.