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California Tank Lines, Inc. Page 2 <br /> 3105 South EI Dorado Street March 3, 2010 <br /> Stockton , California 95206 <br /> The EHD does not approve the advancement of the three proposed soil borings along the <br /> southern perimeter of this site, the proposed soil boring west of Shop No. 6, or the proposed soil <br /> boring directly south of the Wash Rack based on the following : <br /> • Data submitted in reports from 2008 through 2009 indicate that groundwater flow <br /> direction is generally toward the southeast and northeast relative to monitoring well <br /> MW-1 where two diesel underground storage tanks (USTs) were removed in September <br /> 1998 . Since monitoring well MW-3 is down-gradient of MW-1 and groundwater <br /> analytical results for MW-3 have been non-detect for chemicals of concern for at least <br /> one year, the EHD does not believe soil borings are necessary south of MW-3. <br /> Furthermore, during the installation of MW-3 , analytical results for soil samples collected <br /> at fifteen , thirty, and fifty feet bsg were non-detect for chemicals of concern while only <br /> low concentrations of toluene [0.007 milligrams per kilogram (mg/kg)] and total xylenes <br /> (0. 0076 mg/kg) were detected in soil samples collected at thirty-five feet bsg . <br /> • CPT boring P-3 was advanced approximately thirty-five feet southwest of MW- 1 in <br /> October 2007. Analytical results for grab groundwater samples collected at thirty-five, <br /> fifty-five , and ninety-six feet bsg from P-3 were non-detect for chemicals of concern . <br /> Based on these groundwater analytical results, the EHD does not believe additional soil <br /> borings are necessary south and southwest of MWA . <br /> • Proposed soil borings west of Shop No. 6 and south of the Wash Rack are both up- <br /> gradient of the source areas and the EHD believes these two proposed borings are too <br /> far removed from the former USTs to warrant additional investigation . Grab <br /> groundwater samples collected in October 2007 from CPT boring PA , approximately <br /> thirty-five feet west of monitoring well MW-2 where two USTs were removed , were non- <br /> detect for chemicals of concern at sixty, ninety, and one-hundred-twenty-five feet bsg . <br /> Also soil boring B-4, advanced northwest of MW-2 in November 1996 , had non-detect <br /> results for soil samples collected at ten , twenty, and thirty feet bsg , and low <br /> concentrations of benzene and TPH-g in the one grab groundwater sample collected <br /> from B-4. Based on these analytical results, the EHD does not believe it is necessary to <br /> collect additional soil and groundwater samples west and northwest of MW-2. <br /> Please submit an encroachment permit issued by the City of Stockton for the advancement of <br /> the three proposed borings in the City right-of--way on the west side of EI Dorado Street, along <br /> with a boring permit application and permit/inspection fee of $434 to the EHD and complete the <br /> fieldwork by May 14, 2010. Notify the EHD at least a week prior to the scheduled fieldwork. <br /> By letter dated January 12, 2009 , the EHD directed that a sensitive receptor survey report be <br /> submitted by March 4 , 2009 , and a corrective action plan (CAP) that included several methods <br /> for site remediation be submitted by April 6 , 2009 . The EHD also requested contaminant mass <br /> estimates , supported by calculations, for sorbed and dissolved TPH-g, benzene, TPH-d and <br /> TPH-mo. To date, the EHD has not received any of these items . Also, Site Investigation <br /> Results and Site Conceptual Model, dated September 30 , 2008, has not been uploaded to <br /> GeoTracker. Complete the above directives by April 15 , 2010. Prior to unloading Soil Vapor <br /> Survey Report, Human Health Risk Assessment, and Additional Site Investigation Work Plan, <br />