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Mr. Gene Gabbard • . <br /> 640 N.EI Dorado Street <br /> Page 2 of 2 <br /> Mr. Barton noted that additional criteria for closure consideration has been added recently that <br /> must be addressed for CVRWQCB concurrence with a closure request—the San Francisco Bay <br /> Regional Water Quality Control Board (Region 2) Environmental Screening Levels (ESLs) and <br /> California Human Health Screening Levels (CHHSLs) must be considered for closure requests. <br /> In addition, the potential for vapor intrusion into structures on or near the site must be evaluated <br /> and reported. This is particularly important for your site as free product has been present at <br /> shallow depth within the structure on your site. If liquid free product has been successfully <br /> removed from the site, a film of free product stuck on soil grains can be assumed to still be <br /> present, which may volatize over time. The EHD believes that the potential for vapor intrusion <br /> evaluation will require a current estimate of the sorbed mass or concentrations in the former <br /> tank pit area. <br /> At the close of the meeting it was agreed that Mr. Lane would reevaluate the site data with the <br /> objective of addressing the remaining concerns of the EHD and the CVRWQCB noted above. <br /> EHD notes that the resulting report should clearly demonstrate Mr. Lane's interpretation and <br /> effectively minimize alternative interpretations that may be less favorable for closure <br /> consideration. If additional data is required to produce such a demonstration a work plan to <br /> acquire the data must be submitted to the EHD. The EHD notes that lack of reimbursement from <br /> the State Cleanup Fund is not a justification for site closure; for site closure the EHD requires a <br /> professional evaluation of the site that clearly demonstrates that the site poses a low risk to <br /> human health and the environment. <br /> If you have any questions please call Lori Duncan at (209) 468-0337 or Nuel Henderson at <br /> (209)468-3436. <br /> Donna Heran, REHS, Director <br /> Environmental Health Department <br /> l.e�t . <br /> 1 d"� cn tom. '!' <br /> Lori Duncan, Senior REHS Nuel Henderson, PG <br /> LOP/Site Mitigation Unit IV LOP/Site Mitigation Unit IV <br /> cc: James Barton, CVRWQCB <br /> Robert Trommer, SWRCB-CUF <br /> John Lane, Ground Zero Analysis, Inc. <br />