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STATE OF CALIFORNIA—HEALTH AND WELFARE AGENCY GEORGE DEUKME)IAN, GoM <br /> DEPARTMENT OF HEALTH SERVICES <br /> TOXIC SUB:-,^'ANCES CONTROL DIVISION 0 <br /> REGION t September 21, 1989 <br /> 4250 POWER INN ROAD <br /> SACRAMENTO,CA 95826 <br /> (916)7393145 <br /> Mr. Robert W. Chambers <br /> Vice President <br /> Beck Development Company, Inc. <br /> 3114 West Hammer Lane HEALTH <br /> Stockton, CA 95209 ENVIRONMENTAL <br /> PERMITISERVICES <br /> Dear Mr. Chambers: <br /> BECK DEVELOPMENT SITE, TRACY, SAN JOAQUIN COUNTY <br /> We have reviewed the submittal titled "Soil and Groundwater <br /> Assessment Report, Beck Development Company Property, Tracy, <br /> California" , and dated August 7 , 1989 . We find that while the <br /> report contains additional information on metals <br /> concentrations at the site and partially addresses the <br /> ground water investigation issue, it does not enable the <br /> Department to make a determination as to the potential risks <br /> associated with the proposed residential development or the <br /> ways to minimize such risks. <br /> The report, which was not prepared pursuant to a workplan <br /> approved by the Department, contains the results of a further <br /> round of soil sampling for arsenic, chromium, and nickel <br /> levels at the site. The metals analyses indicate much lower <br /> concentrations of arsenic in the soils and tend to validate <br /> the conclusion that the previously reported high values of <br /> arsenic were due to analytical error. However, the <br /> concentrations of these metals in the soils still appear <br /> elevated. The report's conclusion that these levels are <br /> characteristic of soils in the Tracy area was not supported by <br /> any data. No additional analyses for organic pesticides, <br /> which were previously found in elevated concentrations, were <br /> conducted. <br /> The report also addressed 'the installation, development, and <br /> sampling of a deep monitoring well (as described in the site <br /> characterization workplan dated September 7 , 1988 but not <br /> included in the January 25, 1989 report of site <br /> characterization) . We are concerned that the water samples <br /> from this well , as well as the other shallow monitoring wells <br /> at the site, were analyzed only for Total Petroleum <br /> Hydrocarbons (TPH) . We feel that the use of only TPH as an <br /> indicator analysis is not justified in this application <br /> because the detection limit is not low enough to identify <br /> potential contaminants in the parts-per-billion (ppb) range. <br />