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Y - <br /> Mr. Thomas Bauhs • - 3 - • 16 June 2005 <br /> Ms. Kitty Walker <br /> 12. The L&M OU needs to revise the monitoring proposed on page 12 to say that an analyte can be <br /> removed from the sampling schedule if the first two consecutive quarterly results are non-detect <br /> at an acceptable practical quantitation limit. <br /> Comments on the Report <br /> 13. The majority of DTSC's 3 May 2005 comments were not addressed. Based on correspondence <br /> from Mr. Tracy Sizemore, EarthTech will respond to all DTSC comments that are related to the <br /> human health risk assessment. <br /> 14. In the responses to Regional Board staff s 3 May 2005 letter, the L&M OU correctly notes that <br /> Method TO-13 is not appropriate for soil gas analyses for naphthalene. Due to the vapor <br /> pressure of naphthalene, Method TO-13 is theoretically not a good technical choice. Method <br /> TO-15 SIM is technically the optimal available method for assessing naphthalene concentrations <br /> in soil gas, as recently demonstrated by Air Toxics Limited. Method TO-13 is a method for <br /> measuring concentrations of polyaromatic hydrocarbons (PAHs) in air and use of an adsorbent <br /> can trap vapor phase PAHs for quantifying. <br /> 15. Section 3.6 incorrectly refers to boring GP-6. The three Geoprobe borings were labeled as GP-1 <br /> through GP-3. <br /> The goal of the work being conducted is to remediate soil and groundwater to non-detectable or <br /> background concentrations. The work proposed must be in accordance with this goal. By 8 July 2005, <br /> please provide a response to the above comments. Upon completion of the baseline sampling event and <br /> Regional Board staff concurrence of Responses to Comments due by 8 July, the L&M OU may begin <br /> soil vapor extraction system operation. <br /> As of 15 June 2005, Ms. Mary Serra will be the project manager for this site. All submittals and inquires <br /> should be directed to Ms. Serra, who maybe contacted at (916) 464-4682 or mserra@waterboards.ca.gov. <br /> DEVRA LEWIS <br /> Environmental Scientist <br /> cc: Mr. Steven Becker& Jerry Lile, Department of Toxic Substances Control, Sacramento <br /> Mr. Jeffrey Wong, San Joaquin County Environmental Health Department, Stockton <br /> Mr. Tracy Sizemore, ConocoPhillips, Tempe, AZ <br /> Mr. Robert Goodman, Law Office of Robert C. Goodman, San Francisco <br /> Mr. Sean Sherlock, Snell &Wilmer, Irvine <br /> Mr. Derrick Vallance, ConocoPhillips, Houston, TX <br /> Mr. William Brown, Esq.,Daley&Heft, Solana Beach <br /> Ms. Audrey Winters, Attorney at Law, Gold River <br /> Ms. Barbara J. Anderson, City of Stockton, Stockton <br /> Ms. Gretchen Louden, Cesar Chavez Central Library, Stockton <br /> Mr. E.J. Williams, E.J. Williams Property Management, Stockton <br /> Mr. Rusty Benkosky and Clint Harms, SECOR International Incorporated, Sacramento <br /> Ms. Margaret Dahlen, Earth Tech, Sacramento <br /> Mr. Robert Traylor, Golden State Environmental, San Diego <br /> Ms. Susan Meams, Santa Monica <br />