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PUBLIC, HEALTH SERVICES/ p4V!N <br /> SAN JOAQUIN COUNTY <br /> ENVIRONMENTAL HEALTH DIVISION y- <br /> Ernest M. Fujimoto, M.D., M.P.H., Acting Health Officer <br /> 445 N. San Joaquin Street • P. O. Box 388 • Stockton, CA 9520 88c4C%"oR`'�P <br /> 209/468-3420 n n <br /> i <br /> u <br /> STEVE SHINNERS q <br /> YELLOW FREIGHT SYSTEMS APR. 18 1995 <br /> 10990 ROE AVE <br /> OVERLAND PARK KS 66211-1213 <br /> RE: RISK ANALYSIS WORKPLAN FOR YELLOW FREIGHT SYSTEMS <br /> 4520 S HWY 99; STOCKTON CA SITE CODE: 1611 <br /> San Joaquin County Public Health Services, Environmental Health Division (PHS- <br /> EHD) has completed the review of the above mentioned workplan, as prepared by <br /> Denise Clendening, Woodward-Clyde Consultants, Santa Ana office, on April 4, 1995. <br /> Through many telephone conversations with Ms. Clendening, concerns that PHS- <br /> EHD had will be resolved in the final report. Some of the difficulty encountered <br /> during the review process centered on the lack of submitted data gathered during the <br /> initial site investigation. The initial site investigation had been placed on a "fast track" <br /> to accommodate a pending property transfer of ownership. As a result, the <br /> Woodward-Clyde Sacramento office provided additional clarification regarding the <br /> field conditions and the laboratory data received in the field November 11, 1994. <br /> The following concerns were discussed with Ms. Clendening and are in the order in <br /> which they appear in the Workplan. <br /> The "Tri-Regional Board Staff Recommendations for Preliminary Evaluation and <br /> Investigation of Underground Tank Sites" (California Regional Water Quality Control <br /> Boards, Regions 1, 2, and 5) and screening level values in Table 1 of the Los <br /> Angeles Region California Regional Water Quality Control Board's "Interim Site <br /> Assessment and Cleanup Guidebook, Volume 1: Assessment and Cleanup Guidance, <br /> February 1995" are conservative for the protection of groundwater. The Los Angeles <br /> Region document is also protective of direct human health exposure pathways (as <br /> defined by the USEPA methodology referenced in the ASTM Emergency Standard <br /> Guide for Risk-Based Corrective Action Applied at Petroleum Release Sites ES 38- <br /> 94). Alternative soil cleanup levels proposed when supported by the use of risk- <br /> assessment approaches and/or fate and transport modeling must include the <br /> component of groundwater protection because groundwater is considered a receptor <br /> rather than a pathway. <br /> A 70-year time period has been chosen rather than 99- or 100-year time period to <br /> impose conservatism in the results. <br /> A Division of San Joaquin County Health Care Services <br />