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40 <br /> Jeff Wong [EH] <br /> From: Thomas Berg [TBerg@dtsc.ca.gov] <br /> Sent: Friday, February 11, 2005 2:02 PM <br /> To: SJohnson@,gMFurnature.com <br /> Cc: Thomas Kovac; Yugal Luthra; LRFROEBE@niactec.com; Jeff Wong [EH] <br /> Subject: DTSC Certification <br /> Steve, <br /> As we discussed, DISC understands your goal for the AMMC Stockton <br /> facility (Site) is a Certification that all remediation work is <br /> completed with no restrictions on land use. That would provide for <br /> residences to be constructed at the property. <br /> In order to accomplish this, DISC will require that you document that <br /> 100 percent of the Site is free of environmental impacts. A large <br /> portion of this documentation can probably be provided most efficiently <br /> in the Risk Assessment workplan. Many areas of the Site may be covered <br /> by just documenting that no hazardous substances were used in that <br /> portion of the property. The storage warehouses for dry wood would be _ <br /> an example. <br /> Areas of specific concern will need to be handled in greater detail as <br /> we discussed during our meeting on February 9th. These areas include <br /> such facilities as the drainage ditch, groundwater impacts and the burn <br /> pit areas. <br /> Subsequent to our tour of the facility, there were some items observed <br /> that are a concern to DTSC and will need to be addressed before any <br /> certification can be granted. Examples of these things include the <br /> stockpiles of crushed asphaltic concrete and the remaining foundation <br /> from the teepee structure. Asphaltic concrete is a concern because it <br /> is a source of poly nuclear aromatics (PNAs) that can be a health risk. <br /> The foundation of the teepee structure is a concern because the concrete <br /> may be impacted by dioxens or other hazardous substances. These types <br /> materials will have to be removed from the site or sampled and managed <br /> in such a way that they will not be a health concern for future <br /> residences. All of the previous operating facilities will have to be <br /> documented and managed in a similar fashion. <br /> The areas under specific jurisdiction of the San Joaquin County <br /> Environmental Health Department (SJCEHD) will have to be addressed to <br /> there satisfaction. Such things as the hazardous materials used on site <br /> and areas of groundwater monitoring will have to be closed by the <br /> SJCEHD. Please note, meeting the requirements of the SJCEHD does not <br /> mean that any hazardous materials remaining on-site do not present a <br /> threat to human health. The effect on human health will have to be <br /> established by the risk assessment. <br /> The "standard" for a clean certified Site would be one that is stripped <br /> down to the rough grade and can be sampled for specific concerns from <br /> previous operations. However, the AMMC property is currently operating <br /> and has numerous foundations and installations left in tact. DTSC will <br /> not be able to provide a certification letter before all these <br /> installations and operations are abandoned and cleaned (if needed) . <br /> Additionally, NO ADDITIONAL "UNKNOWN" materials should be brought on the <br /> Site. <br /> The comprehensive Risk Assessment workplan will be a good first step in <br /> this entire process. <br /> In order to better manage the Site certification, DISC may suggest some <br /> type of phased approach. It is a common practice to develop a "Closure <br /> 1 <br />