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w <br /> LEE & PIERCE inc. <br /> consulting engineeps <br /> CIVIL•ENVIRONMENTAL•AGRICULTURAL <br /> 546 ABBOTT ST,STE 20 _ 334 S YOSEMITE AVE,STE Al <br /> SALINAS,CA.93901-4373 OAKDALE,CA.95361-3967 <br /> (831)758-0096 PHONE (209)848-8270 PHONE <br /> (831)758-1213 FAX (209)848-8274 FAX <br /> boelichWeeandoiercexom ilaneolleeandoierce.com <br /> January 11, 2012 c <br /> Ms. Lori Duncan RECEII .- <br /> San Joaquin County v <br /> Environmental Health Department JAN 17 2012 <br /> 600 East Main Street <br /> Stockton, CA 95202-3029 ENVIRONMENTqLH <br /> PERMIT/SERVICES TM <br /> RE: Fremont Gate LLC, 2911 East Fremont Street, Stockton, CA <br /> L&P #10759 <br /> Dear Ms. Duncan: <br /> Lee & Pierce, Inc. (L&P) is responding to your letter dated December 15, 2011 regarding the United <br /> Rentals site located at 2911 E. Fremont Street, Stockton, California. The December 15, 2011 letter was <br /> prepared by San Joaquin County Environmental Health Department (EHD) in response to L&P's <br /> November 15,2011 summary report related to the site. EHD presented several concerns it had regarding <br /> the report. L&P has prepared the following response to each concern stated in your letter. <br /> 1. Please explain how can one determine whether or not the detected contaminants were from either <br /> impacted soil beneath the building or the vehicle parked within the building, or that they are a <br /> combination of these two—or more—potential sources? <br /> L&P Response: The detected contaminants in the air samples collected within the warehouse provide a <br /> snapshot of the chemicals that were present in the air during the day of sampling. The assumed potential <br /> sources of chemicals include subsurface contaminants volatilizing into the building,chemicals related to <br /> ongoing site operations (such as refueling vehicles very near the building), and ambient sources(such as <br /> vehicular traffic on surface streets or at the site itself). There are no other known potential sources. The <br /> purpose of the air sampling and evaluation was to determine if the chemical make up of indoor air differed <br /> substantially from the chemical make up of ambient air and,if so,if the concentrations of chemicals in air <br /> at the site pose undue risk to site workers. The fact that benzene was present at levels exceeding indoor air <br /> CHHSLs in all samples collected at the site (indoor and outdoor air samples) prompted additional, site <br /> specific evaluation(Tier 2). Regardless of the source of contaminants in indoor and outdoor air at the site, <br /> the Tier 2 evaluation estimated a site specific cancer risk of between 4.0E-6 and 1.7E-6, which is <br /> marginally above the 1.0E-6 considered by most regulatory agencies as having essentially negligible risk, <br /> ?j y and in the lower range of what may be considered acceptable in a commercial setting(1.0E-4 to 1.0E-6). <br /> 2. EHD considers the number of samples too small to make a statistical interpretation that the two ambient <br /> samples and the two indoor samples had different sources and does not think it follows that even if the <br />