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California Tank Lines, Inc. Page 3 <br /> 3105 South El Dorado Street January 12, 2009 <br /> Stockton, California 95206 <br /> WRM has recommended the following: <br /> • Prepare a human health risk assessment that includes a sensitive receptor survey. <br /> • Conduct a soil vapor survey. <br /> • Prepare a natural attenuation assessment to determine the time needed for natural <br /> attenuation to achieve water quality objectives. <br /> • Review chromatograms of TPHg and TPHd and mass spectra data from all four <br /> monitoring wells for comparison of similarities and differences, and indicators of <br /> weathering. <br /> • Prepare a closure report if results from the above recommendations demonstrate <br /> acceptable levels of risk. <br /> The EHD approves preparation of a human health risk assessment and a sensitive receptor survey <br /> report that includes surface water bodies, schools, as well as domestic, municipal, industrial and <br /> other wells within a 2,000-foot radius of this site. Contact the Department of Water Resources, <br /> municipal water suppliers, and nearby industries for well information. Perform a physical search <br /> of the area to identify all wells, and show the location of all wells on a map, relative to the <br /> location of this site and submit any known construction details of the wells to the EHD by March <br /> 4, 2009, <br /> The Central Valley Regional Water Quality Control Board is requiring evaluation of <br /> Environmental Screening Levels (ESLs), California Human Health Screening Levels (CHHSLs), <br /> San Francisco Bay Regional Water Quality Control Board) and the potential for vapor intrusion <br /> into buildings for closure consideration of sites having residual contamination left in place; <br /> therefore, the EHD concurs that a soil vapor survey is warranted that includes the evaluation of <br /> ESLs, CHHSLs, and the potential for vapor intrusion into the existing onsite buildings . Submit <br /> to the EHD by March 4, 2009, either a work plan to assess the potential for vapor intrusion into <br /> the existing onsite buildings, or a rational, with technical support, for discounting vapor intrusion <br /> into the buildings as a potential hazard for this site. <br /> Based on high concentrations of TPHg, benzene, and 1 ,2-dichloroethane ( 1 ,2-DCA) detected in <br /> groundwater from boring P2 at 35 feet bsg; the possible high concentrations of 1 ,2-DCA <br /> detected in groundwater from boring S-5 at 65 feet bsg; high concentrations of TPHd and <br /> TPHmo detected in groundwater collected from MW-2, and high concentrations of TPHg, <br /> benzene, and 1 ,2-DCA detected in groundwater collected from MW-4 during the quarterly <br /> groundwater monitoring events, instead of submitting a natural attenuation assessment, the EHD <br /> directs that a corrective action plan be submitted to the EHD by April 6, 2009, that includes <br /> several methods for site remediation. Please include contaminant mass estimates, supported by <br /> calculations, for sorbed and dissolved TPHg, benzene, 1 ,2-DCA, TPHd, and TPHmo. The <br /> recommended remedial technology should be well supported by an analysis for cost- <br /> effectiveness . <br />