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XAM-Dr%A-CHN WHiMM VMi VIZ) 7lb de( 4-z47 F''. 0—*/WD <br /> Fwmer Texaco,Lodi %%W� ' <br /> Page 2 <br /> Speculating that pm 1979 LMreleases may,have contributed to detectable <br /> dichloroethane in groundwater beneath the Togo's site,Regional Beard 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 /> I c�wever, dichloroethane is a very common industrialchemical which is widely <br /> used in the following applications: fbtmulation of TCC and vinyl chloride; lead. <br /> scavenger in "anti�knook"gasoline; paint or va.rniskremover; metal degreaser;. <br /> snaps and-scouring Mnpounds; and fumigants. It is also a recognized n*01 <br /> bi€��n breakdown product of chlorinated solvents,including PCE ani. <br /> TCE. Indeed the Cetunty and the consultant for Togo's baveconcluded that <br /> dote tWo dichloroethatne in groundwater beneath andup-,down and cross!. <br /> gradim'f m Togo'0.site is most likely attributable to the pervasive dry cleaner. <br /> solve»ts plui�a��. <br /> The dispate between County and Regional Board LUFT staff centers around <br /> whe error»ot.responsible parties in the existing Togo's case should expend <br /> additional`ntoriey and effort in further subsurface investigations,sampling,and <br /> analysis with respect to dichloroetliane(lar for that matter,any other fuel <br /> constituent). Section 132o of the+California Water Code requires that aq request <br /> for.such technical infttirntation must ensure that the cost ofobtain ng the technical <br /> nfornriation is consistent with the benefit to be gained by it <br /> C„�rmclu�i�ns <br /> 1:concur with the County staff that the time-series data(going to"non-de#ecf' <br /> B=in most recent sampling) and the distance to nearest watersupply well <br /> (2,0100 ft upgradient}-constitute substantial evidence that residual petroleum <br /> constituents in soil or groundwater pose a "low risk." l believe the County has <br /> correctly concluded that any residual petroleum constituents which may.remain <br /> from the:decades old LUFT release at this site pose a"low risk" in accordance <br /> with the recommendations in Walt Pettit`s December 8, 1995 letter. <br /> Finally, :lacking any identified water quality benefit to additional,costly site <br /> assessment,the County's recommendation for"no further action."is fully <br /> consistent with Water Code Section 13267. It is clear from the facts that <br /> substantial evidence its the record and reasonable,technically defensible <br /> conclusions drawn from that evidence support"no further regulatory action." <br /> 10, <br /> OD Afty a pager lArr a at"wit is tojivvierveand twhiante the quality of Cattfnrnia's w*i00-M-Murees.amf <br /> enure dmrprryter attocivionarrd qrIClent use for Ar benef tt cf prannt aruf future 8MffMidit& <br />