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0 0 <br /> San Joaquin County <br /> Environmental Health Department DIRECTOR <br /> .o Donna Heran,REHS <br /> r. 1868 East Hazelton Avenue <br /> PROGRAM COORDINATORS <br /> Stockton, California 95205-6232 Robert McClellon,REHS <br /> -- Jeff Carruesco,REHS,RDI <br /> Kase• cq ,.��,j�P . Website: www.Slgov.org/ehd Linda Foley,REHS <br /> /FOR Phone: 209 468-3420 Linda yEstrTurkaftEstrada, <br /> ( ) Rodney Estrada,RENS <br /> Fax: (209)464-0138 Adrienne Ellsaesser,REHS <br /> September 23, 2014 <br /> Messrs. Kirk Larson, PG, and Robert Trommer, CHG <br /> State Water Resources Control Board <br /> PO Box 100 <br /> Sacramento, CA 95812-0100 <br /> Subject: 1600 W. Durham Ferry Road, Tracy, CA <br /> Third Review Summary Report Closure Response CUF Claim No 8475 <br /> San Joaquin County Environmental Health Department (EHD) has received and reviewed the <br /> Third Review Summary Report (RSR) for Claim No. 8475, dated August 2014 from Kirk Larson <br /> and Robert Trommer of the State Water Resources Control Board (SWRCB) Cleanup Fund <br /> (CUF) for the above-referenced site. The CUF evaluated and commented on the impediments <br /> to case closure identified by the EHD and recommended that the EHD direct the responsible <br /> party to conduct targeted groundwater remediation in the vicinity of MW-2. <br /> The CUF commented on five Low-threat Underground Storage Tank Case Closure Policy <br /> (Policy) criteria identified by the EHD as impediments to case closure, concurring with the EHD <br /> that the site is not within the service area of a public water system and that the case does not <br /> meet the Policy groundwater criteria. The CUF did not concur with the EHD determination that <br /> criteria pertaining to removal of the secondary source, the potential for vapor intrusion, or direct <br /> contact were not met. <br /> The CUF performed a site-specific risk assessment for the site and determined that residual <br /> contamination in soil will have no significant risk of adversely affecting human health, which the <br /> EHD accepts as the portion of the site of known impacted soil is mostly paved or has a building <br /> on it. The CUF also determined that the secondary source as defined by the Policy was <br /> removed by excavation in 2001, which, based on the Policy definition, the EHD also accepts, <br /> but the EHD is still of the opinion that the vapor intrusion issue has not been adequately <br /> addressed. <br /> The CUF found that the case passes the vapor intrusion criteria by scenario 3a, stating that <br /> maximum benzene concentrations in groundwater are less than 1,000 micrograms per liter, the <br /> maximum depth to groundwater is more than 10 feet and the overlying soil has less than 100 <br /> milligrams per kilogram (mg/kg) total petroleum hydrocarbons (TPH). The EHD is concerned <br /> that impacted soil extends under the building on site and that the criteria of scenario 3a may not <br /> fully apply. <br /> The January 2002 report on the over-excavation of soil impacted in the former underground <br /> storage tank (UST) area, described the excavation and noted for the eastern portion, near the <br /> onsite building, "...contamination started a few feet below ground surface and extended deeper <br /> 2014 Third Review Summary Report Response CUF Claim No 8475.doc <br />