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i <br /> Former Texaco,Lodi <br /> Page-2 <br /> Speculating that pre-1979 LUFT releases may have contributed to detectable <br /> dichloroethane in groundwater beneath the Togo's site, Regional Board staff stated <br /> that ". if no 1,2 DCA is detected in soil samples above the 1979 water level,we <br /> will concur with site closure...." but without such data ", .we cannot rule out the <br /> possibility that the Togo's site is a source.-..." <br /> However,dichloroethane is a very common industrialchemical which is widely <br /> used in the fallowing applications- formulation of TCE and vinyl chloride; lead <br /> scavenger in"anti-knock"gasoline; paint or varnish remover, metal degreaser, <br /> soaps and scouring-compounds; and fumigants. It is also a,recognized natural <br /> biodegradation breakdown product of chlorinated solvents,including PCE and <br /> TCE. Indeed, the County and the consultant for Togo's have concluded that <br /> detectable dichloroethane in groundwater beneath and up-,down-, and cross- <br /> gradient from Togo's site is most likely attributable to the pervasive dry:cleaner <br /> solvents plume. <br /> The dispute between County and Regional Board LUFT staff centers around <br /> Whether or not responsible parties in the existing Togo's case should:expend <br /> additional;money and effort in further subsurface investigations, sampling, and <br /> anal ysis .ltli.respect to dichloroethane(or for that matter, any other fuel <br /> constituent). Section13207 ofthe California"Water Code requires that anyrequest <br /> for such tochntcal information.must ensure that the cast of obtaining the technic <br /> al. <br /> lnfortnation is consistent:with:the benefit to be gained by it.: <br /> Conclusions <br /> I concur with<the County staff"that the time-series data(going to "non:detect <br /> BTEX <br /> inmost recent.sarnpling) and the distance to nearest water supply veil <br /> MOO tt upgradido constitute substantial evidence that residual petroleum <br /> constituents in soil or groundwater pose a "low risk." I believe the Oauw hag <br /> correctly concluded thatanyresidual petroleum constituents which may remain. <br /> f bfti the decades c►1d LUFT release at this site pose a"low risk in.accordance <br /> with the recommendations in Walt Pettit's December 8, 19 5 letter. <br /> Finally, lacking any identified water quality benefitto additional,.:costly site <br /> assessment;the County's recommendation for "no further action"is fully <br /> consistent with Vater it. Section 13267. It is clear from the:facts that <br /> substantial eyidence in.the record and reasonable, tecb:nically defensible. <br /> conclusions drawn front that evidence support "no furtherregulatory action." <br /> i <br /> 7 'Recyeled Paper Our missl6n:.is:.ru,preserveanct enhance lite quality 4f California'F water resaurees,and: <br /> +� ensure:their:proper:allocation and efficient use for the benefit o1present and fid&re.genemtidris: <br />