SITE INFORMATION AND CORRESPONDENCE

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Lee Higgins -3- 10 August 2011 Chevron Tracy Byron Road direct exposure pathway to chemicals of potential concern (COPCs) was considered incomplete and the report did not quantitatively evaluate that pathway in the HHSE. The City of Tracy Municipal Code, for administrative reasons unrelated to petroleum impacts, prohibits the use of shallow groundwater wells for domestic or municipal use. Domestic and municipal water services are provided by the City of Tracy. SAIC evaluated the California Department of Fish and Game March 2011 database for threatened, endangered, or sensitive species. Two threatened species were noted at or just beyond, the one-mile radius of the project site. The City of Tracy General Plan notes that this area of the city will be developed for industrial, commercial and office uses near Interstate 205, and some residential uses further from the project. SAIC concluded the ecological screening indicates that a threat to ecological receptors does not appear to be present. Based on my review of SAIC's HHSE report, the following comments are provided: • Consistent with other OVP/TAOC sites, a site-specific Soil and Groundwater Management Plan (SGMP) needs to be submitted. • Central Valley Water Board staff concurs with the findings of the HHSE, and that the Site is a candidate for closure. A request for a No Further Action Required (NFAR) determination may be prepared. • Due to overall length of this project (7,000 feet) and the spacing between the different areas of delineation, separate NFAR documentation and SGMP's should be completed for each area. • Area 2 includes the Surland Homes/Bridle Creek project and DTSC staff will be providing review comments to a previous health risk assessment for Surland Homes. The DTSC review status is not known. The NFAR for Area 2 should be completed for the remaining portion without the Surland Homes risk assessment. • Documentation to support a NFAR closure determination should be completed in accordance with California Regional Water Quality Control Board, Central Valley Region's 16 April 2004 update to Appendix A of the Tri-Regional Board Staff Recommendations for Preliminary Investigation and Evaluation of Underground Tank Sites - No Further Action Requests. Section 6.5 - NFAR for Cases Exceeding Water Quality Objectives should be followed for documenting Site conditions.