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(2119) <br /> www.secor cam <br /> INTER ATIONAL 3017 Ki'gore RRad,Suite 100 <br /> S E C O R INCORPORATED Rancho Cordova,CA 96870 <br /> 916-861-0400 TEL <br /> 916-861-0430 FAX <br /> June 29, 2007 <br /> Ms. Lori Duncan <br /> San Joaquin County Environmental Health Department <br /> 600 East Main Street S� �j <br /> Stockton, California 95202-3029 <br /> O <br /> Re: Request for Site ClosureG � <br /> ARCO Station#6080 <br /> 85 Louise Avenue <br /> Lathrop, California 95330 <br /> SECOR Project No.: 77BP.06080.01.0636 <br /> Dear Ms. Duncan: <br /> This letter, prepared by SECOR International Incorporated (SECOR) on behalf of Atlantic <br /> Richfield Company, a BP Affiliated Company, addresses the comments in the San Joaquin <br /> County Environmental Health Department(SJCEHD)letter dated May 3,2007(Attachment 1). <br /> The SJCEHD letter was prepared in response to the URS Corporation Request forSite Closure <br /> dated February 20, 2006. <br /> RESPONSE TO RWQCB LETTER I <br /> SJCEHD's comments are in bold italics with SECOR's response below. <br /> San Joaquin County Environmental Health Department(SJCEHD)informed you that to <br /> continue their review for closure of the above referenced underground storage tank site <br /> the Regional Water Quality Control Board, Central Valley Region(C VRWQCB)requested <br /> an assessment of the soil contamination remaiing at the site for vapor emission, direct <br /> exposure and gross contamination. Concentrations of xylenes and total petroleum <br /> hydrocarbons as gasoline(TPHg)in shallow soil near the dispenser islands at this site <br /> exceed the San Francisco Bay Regional Water Quality control Boards Tier t <br /> Environmental Screening Levels(ESLs)for evaluation of risk posed from remaining soil <br /> and groundwater contamination. <br /> Please proceed with preparation of the assessment and submit to SJCEHD. Include in <br /> the assessment a discussion of the expected long-term use of the site,which addresses <br /> specifically that the use of the land will limit the risk from residual contamination i.e. j <br /> ARCO expects the site to be an operating gas station for the foreseeable future. <br /> The SECOR Risk Based Corrective Action (RBCA) Analysis for ARCO 6080 is included in <br /> Attachment 2. ARCO 6080 is currently expected to continue to operate as a gas station and <br /> there are no plans to change the site use. The plume is stable with an annual decrease in <br /> contaminant concentration trends. In addition, there are no current or anticipated uses of the <br /> impacted groundwater within the timeframe projected to meet the water quality objectives. <br /> hBP-ARC0104 BP Valley Portfolio\BP Valley Sites160801Reports\Closure report16080 Response to Closure <br /> Comments.doc <br /> I <br />