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Ernesto Renteria, Jr. <br /> April 1, 2015 <br /> Pimentel Property Page 3 of 4 <br /> 1650 S. EI Dorado Street <br /> Stockton, CA 95219 <br /> reports with the QA/QC data were provided, but there are still some information gaps that the EHD <br /> will request AGE to complete. <br /> Regarding the soil gas results, the CVRWQCB was concerned with the location of the sampling <br /> points relative to the former location of the dry cleaning equipment, which would be the more <br /> probable location of leaks. As the former location of the equipment was not provided, there is some <br /> uncertainty that the one vapor point sampled in the former dry cleaning area was near the point <br /> most likely to have been at a release point; the EHD is of the opinion that this uncertainty can be <br /> reduced by identifying the location(s) of the former dry cleaning equipment or increasing the number <br /> of sampling points in the former dry cleaning facility building footprint. It seems a bit surprising that <br /> the one soil gas sample not to contain detectable concentrations of PCE was the one collected <br /> within the suspected footprint of the former facility building. The EHD also recommends sampling <br /> along the former sewer line if it still exists and its location can be determined; the CVRWQCB also <br /> recommends videotaping the sewer line interior to identify potential release points to guide the <br /> selection of sampling points. <br /> The CVRWQCB thought the sample with a high leak-detector concentration should be resampled, <br /> and that a five-foot sample depth may be more appropriate; the EHD agrees. The deeper, standard <br /> depth may help minimize the potential compromising of sample integrity by leakage of atmospheric <br /> air. Any additional soil gas sampling should incorporate a methodology for quantifying the effects of <br /> atmospheric leakage, if detected, on the analytical results. <br /> The soil and groundwater data collected from boring B3 shows that there was a release in the area <br /> of the possible former UST system and the soil discoloration, odor and analytical data demonstrated <br /> that the boring was located in or near a point of release. The lack of detectable BTEX in the B3 soil <br /> samples is consistent with an aged, biodegraded petroleum fuel release, as is the lack of benzene <br /> and minimal toluene, ethylbenzene and xylenes in the B3 groundwater sample. However, the <br /> sample does show that groundwater was impacted by the release. As groundwater has been <br /> impacted, current practice is to determine the depth of the impact as well as the lateral extent. The <br /> depth, or vertical extent, of impacted groundwater has not been demonstrated, however, if it can be <br /> shown that the groundwater samples collected from 131, B2 and/or B7 are downgradient of B3 and <br /> are from the sandy interval encountered at 35 feet below surface grade (bsg) in B7, and deeper <br /> contamination is not encountered, the EHD will consider the lateral extent of impacted groundwater <br /> to be adequately demonstrated at this time. <br /> As stated by AGE, the concentrations of contaminants encountered during the investigations <br /> described above do not exceed the ESLs and CHHSLs screening levels used to identify a variety of <br /> environmental concerns; however the EHD cannot issue a letter stating that the investigation of <br /> possible UST and dry cleaning releases is complete and that no additional investigation would be <br /> useful or appropriate until the following items have been adequately demonstrated: <br /> • All data QA/QC elements have been reported and are satisfactory, <br /> • The soil gas sampling density in the former dry cleaning facility building footprint is sufficient <br /> for reasonable confidence that any releases from the equipment or plumbing have been <br /> detected; <br /> • The vertical and lateral extent groundwater impacted by the suspected UST release has <br /> been delineated; and <br />