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t <br /> San Joaquin County <br /> .� Environmental Health Department DIRECTOR <br /> Donna Heran,REHS <br /> r. 1868 East Hazelton Avenue <br /> Q: <br /> Stockton California 95205-6232 PROGRAM COORDINATORS <br /> T ' Robert McClellon, REHS <br /> Jeff Carruesco, REHS,RDI <br /> 4�rFOR�` Website: www.sjgov.org/ehd Kasey Foley, REHSLinda Turkatte,REHS <br /> Phone: (209)468-3420 Rodney Estrada,REHS <br /> Fax: (209)464.0138 Adrienne Ellsaesser,REHS <br /> May 14, 2013 <br /> Ken Gillies <br /> Gillies Trucking <br /> P O BOX 8303 <br /> Stockton, CA 95208 <br /> Subject: Gillies Trucking <br /> 3931 Newton Road <br /> Stockton, CA 95205 <br /> The San Joaquin County Environmental Health Department (EHD) has received and <br /> reviewed Remediation Feasibility Study and Connective Action Plan (RFS&CAP), dated <br /> December 2012, prepared by your consultant, Stephen Muir of Stephen G. Muir, Consulting <br /> Geologist and Geophysicist (Muir). The RFS&CAP was prepared in accordance with the <br /> EHD directive by letter dated 10 September 2012 to prepare the document following review <br /> of the report on the soil vapor extraction pilot test conducted in 2011. <br /> In the RFS&CAP, based on the results of the pilot test, Muir recommended remediation <br /> utilizing soil vapor extraction (SVE) with insitu air sparging (IAS) in the source area. Muir also <br /> noted that at the time the CAP was being prepared, the SWRCB had initiated changes in site <br /> closure criteria to include low-risk sites where groundwater contamination by petroleum <br /> hydrocarbons were still present at concentrations above their maximum contaminant levels <br /> (MCL). Muir also noted that groundwater cleanup should be considered complete when it <br /> could be shown that: 1) the plume is stable or shrinking; 2) natural attenuation will achieve <br /> cleanup (goals) within a reasonable timeframe; and 3) significant threats to human health <br /> and the environment have been removed. <br /> The EHD has been reassessing the need for active remediation at your site and considering <br /> site closure as: <br /> • The estimated cost for implementing SVE and IAS as the remedial technologies for <br /> your site could be as much as $195,000.00, and possibly more, and the potential for <br /> significant contaminant mass removal is modest; <br /> • The recently adopted Low-threat Closure Policy (LTCP) of the California State Water <br /> Resources Control Board (SWRCB) are being implemented and are now better <br /> understood; and <br /> • Groundwater at your site is mainly impacted by total petroleum hydrocarbons <br /> quantified as diesel (TPHd) with minimal concentrations of volatile organic <br /> compounds (VOCs) such as benzene, toluene, ethylbenzene and xylenes (BTEX). <br /> The EHD discussed your site status with a representative of the Central Valley Regional <br /> Water Quality Control Board (CVRWQCB) on 11 April 2013 and again on 09 May 2013, and <br /> NFAR Directive Letter 0513 <br />