SITE INFORMATION AND CORRESPONDENCE

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San Joaquin County Environmental Health Department p? c DIRECTOR Donna Heran, REHS .- 600 East.Main Street a: .-A 600 COORDINATORS — t3...s Stockton, California 95202-3029 Robert McClellon, REHS Jeff Carruesco, REHS, RDI Website: www.sjgov.org/ehd Kasey Foley, REHS F o R Linda Turkatte, REHS Phone: (209) 468-3420 Fax: (209) 464-0138 April 16, 2012 Ms. Yvonne Miller A.R. and M.E. Glover Trs. Fayette Manufacturing Corporation P.O. Box 336 Tracy, CA 95378 Subject: Former Fayette Manufacturing 7675 W. Eleventh Street Tracy, California The San Joaquin County Environmental Health Department (EHD) has reviewed various reports and data for your site, including Site Conceptual Model (SCM), dated 05 May 2011, and Subsurface Soil, Groundwater, and Soil Vapor Investigation Report (Soil Vapor Report) dated 19 May 2008, both prepared by your consultant ATC Associates, Inc. (ATC) for the above- referenced site. The EHD has also received and reviewed the draft recommendations for your site issued by the State Water Resources Control Board Cleanup Fund Five-Year Review Committee, who recommended consideration of your site for closure. Based on the results of the Johnson and Ettinger model presented In the Soil Vapor Report, which indicated an elevated carcinogenic risk and health hazard related to chemicals of concern (COCs) in soil gas, the EHD and ATC have been evaluating potential remediation technologies to address the COCs and reduce the risk and hazard. Most other potential concerns on the site have been adequately addressed. During this review, it was noted that the elevated carcinogenic risk and health hazard may be due in ;part to the inclusion of chemicals not normally associated with storage and use of petroleum fuels in underground storage tank (UST) systems (such as methylene chloride, acetone, styrene, methyl ethyl`kelone, 1,3-butadine and carbon disulfide), and the inclusion of undetected COCs. at concentrations equal to one-half the chemicals' reporting limit concentrations-, this may have yielded elevated risk and hazard levels. To assist the EHD reevaluation of your site fora low-threat closure, please recalculate the carcinogenic risk and health hazard posed by COCs actually detected and quantified from soil gas samples, and that are commonly associated with petroleum fuels. Provide the report of findings to the EHD by 18 June 2012. If the findings are favorable, you may request case closure and include the closure criteria in Appendix A of the Tri-Regional Guidelines, also include an estimate of the time required for impacted groundwater to achieve water quality objectives (WQOs). I Directive to Reevaluate Soil Gas Data