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San Joaquin County <br /> Environmental Health Department DIRECTOR <br /> Donna Heran, REHS <br /> r. 1868 East Hazelton Avenue <br /> PROGRAM COORDINATORS <br /> Stockton, California 95205-6232 Robert McClellon,REHS <br /> Jeff Carruesco,REHS, RDI <br /> • c'q' ..,,,,�• '�P Website: www.sjgov.org/ehd Foley, REHS <br /> Linda <br /> Linda Turkatte, REHS <br /> Phone: (209)468-3420 <br /> Fax: (209)464-0138 <br /> July 29, 2014 <br /> Charanjit S. & Davinder K. Jutla <br /> 3940 N. Tracy Boulevard Site Code: 0001953 <br /> Tracy, CA 95304 <br /> Subject: Tracy Truck&Auto <br /> 3940 N. Tracy Boulevard <br /> Tracy, CA 95304 <br /> The San Joaquin County Environmental Health Department (EHD) has reviewed Site Closure <br /> Summary Report for the Former Underground Storage Tank Diesel Dispenser Island Leak <br /> Investigation Area Located at the Tracy Truck Stop, 3940 N. Tracy Boulevard, Tracy, California, <br /> 95306, dated 12 June 2014, prepared by Environmental and Hydrogeological Consulting (E&HC) <br /> on your behalf. The EHD also reviewed your Petition for UST Site Closure for the Former <br /> Underground Storage Tank Diesel Dispenser Island Leak Investigation Area Located at the Tracy <br /> Truck Stop, 3940 N. Tracy Boulevard, Tracy, California, 95306 (Petition), dated 11 June 2014. In <br /> addition, the EHD has reviewed previous reports for your site and the former leaking underground <br /> storage tank (UST) sites at 3725 N. Tracy Blvd. (Arco), 3775 N. Tracy Blvd. (Chevron), 3788 N. <br /> Tracy Blvd. (former Unocal), and the still active case site at 425 W. Larch Road (Frontier), to better <br /> evaluate your closure request and appeal. The California State Water Resources Control Board <br /> (SWRCB) will respond to the Petition, but the EHD considered the closure justifications in the <br /> Petition. <br /> The EHD concern with closing your site at this time has to do with the adequacy of the <br /> characterization of the contaminant distribution in the subsurface that resulted from the <br /> unauthorized release (UAR) from the dispensers of your UST system, especially as there are <br /> drinking water wells in the area that are still in use or could potentially be put into use, and it is the <br /> objective of the EHD to protect those wells from being impacted by the UAR after your site is <br /> closed and not under investigation. A critical element of evaluating the risk to those wells and other <br /> sensitive receptors is an adequate characterization of the subsurface impact from the UAR, <br /> including the vertical and lateral extent of impacted soil and groundwater. This is most important in <br /> the down-gradient flow direction of groundwater, and due to conflicting data on the groundwater <br /> flow direction on nearby sites, there is uncertainty with what is the actual flow direction on your site; <br /> therefore the EHD does not have a high level of confidence that impacted soil and groundwater on <br /> your site has been adequately delineated. <br /> Your previous consultant, Cardno ATC, placed borings SB-1, SB-2 and SB-3 east of the dispenser <br /> islands based on groundwater flow directions determined at the Arco and Chevron sites, where <br /> flow was predominantly toward the northeast, but data from the former Unocal site (flow <br /> predominantly toward the northwest) and Frontier site (flow predominantly toward the northwest to <br /> southwest) causes the uncertainty as your site is at the confluence of these flow directions, as <br /> described in the EHD letter dated 3 April 2014. The EHD is of the opinion that there is a significant <br /> Case Closure Denial and Directive Letter 0714 <br />