SITE INFORMATION AND CORRESPONDENCE

Home Browse Search

Harlin Knoll [EH ] From: Nuel Henderson [EH] Sent: Monday, September 23, 2013 1:34 PM To: 'Waite, Brian A' Cc: Harlin Knoll [EH]; Adrienne Ellsaesser [EH] Subject: RE: Low Threat Closure Request for 575 W. Grantline Rd., Tracy, CA r Dear Mr. Waite, ` Please accept my apologies for not responding sooner; I was unsure if Harlin had already responded . I spoke to Harlin today regarding your inquiry and he said he had not responded to you yet as he wanted my input. I 'll try to address your issues. Addressing the issue of vapor intrusion has become more prominent in recent years in my opinion , and the issue is recognized as a significant criterion in the Low Threat Closure Policy (LTCP) adopted last year by the California State Water resources Control Board , and must be adequately addressed for site closure. In our county, the Tracy area seems to be the main area where vapor intrusion has emerged as a potential issue, I think maybe due to the shallow depth to groundwater in the area , but there may be other controlling factors. Your site has high contaminant concentrations in soil gas compared to most other sites in the county, exceeding screening concentrations as was noted in our letter of 18 June 2013. Before my agency can close your site, it must be demonstrated that the soil gas contaminant concentrations will not pose a significant health risk or hazard to occupants of the site. The EHD does not have the in-house expertise to make this demonstration so must rely on the technical skills and abilities of your consultants to make the technical demonstration for current and potential future property use. Regarding your second question , our agency had heard that the LTCP requires review of LTCP requests within 60 days of receiving them . We have further heard that if we cannot or do not respond to such requests within the 60-day period it is considered a denial of the request and is automatically appealed to State Board for review. I 'm not sure how this appeal is generated automatically, but you are certainly within your rights to file an appeal directly yourself or though your i consultant. i. Please be assured that this agency will move your site toward closure as expeditiously as possible, but we do need to have the potential vapor intrusion issue adequately addressed. If I can provide any other information, please let me know. Nuel Henderson From : Waite, Brian A [mailto : BWaite@chevron .com] Sent: Friday, September 13, 2013 1 :40 PM To: Harlin Knoll [EH] Cc: Herzog, David; Nuel Henderson [EH] ; Adrienne Ellsaesser [EH] ; Barton, Jim@Waterboards; Allen, Nathan Subject: RE: Low Threat Closure Request for 575 W. Grantline Rd ., Tracy, CA Harlin , Thank you for your quick response. CRA mentioned a potential concern that you had regarding vapor intrusion into a modular home without a foundation on the subject property. I will take a look in GeoTracker to look at your technical justification for requiring this. I recall hearing from Kevin Graves and others at the SWRCB that the Plan for Implementation of Low Threat Underground Storage Tank Closure Policy and Additional Program Improvements, approved by Resolution 2012- 0062 includes a requirement that all RWQCB's and LOP's review all LTC Requests within 60-days of receiving them . Is this the same message that you are hearing? Regards, Brian A. Waite, P . G . i Project Manager 1