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4 • <br /> California Regional Water Quality Control Board <br /> vCentral Valley Region ' <br /> Robert Schneider,Chair <br /> Alan C.Lloyd Ph.D. Arnold Schwatzenegger <br /> Secretary for Sacramento Main Office ��� p��ernor <br /> Environmental Internet Address: httpJ/www.waterboards.ca.gov/centrals-611 �� \\VJI <br /> Protection 11020 Sun Center Drive#200 Rancho Cordova,CA 95670-6114 �IUiv(�Y <br /> Phone(916)464-3291 Fax(916)464-4797 <br /> 3 May 2005 <br /> MM 0 <br /> PERMIT/SERVICES <br /> Mr. Thomas Bauhs Ms. Kitty Walker <br /> Chevron Environmental Management Company Stockton Department of Housing &Redevelopment <br /> P.O. Box 6012 305 North El Dorado Street, Suite 200 <br /> San Ramon, CA 94583-0904 - Stockton, CA 95202 <br /> REVIEW OF RESPONSE TO COMMENTS, SOUTH SHORE PARCEL 2A, <br /> 666 WEST WEBER AVENUE, STOCKTON,SAN JOAQUIN COUNTY <br /> Staff of the Central Valley Regional Water Quality Control Board(Regional Board)reviewed the <br /> 8 April 2005 Response to RWQCB Letter Dated March 16, 2005 (Response to Comments) <br /> submitted by SECOR International Incorporated(SECOR) on behalf of the L&M Operable Unit <br /> (OU) for a portion of Parcel 2A of the South Shore Parcels along West Weber Avenue in <br /> Stockton (site). Golden State Environmental (GSE), on behalf of the City of Stockton's <br /> Department of Housing and Redevelopment (RDA) also reviewed the Response to Comments <br /> and those comments are attached. The Response to Comments replies to Regional Board staffs <br /> 16 March 2005 letter(Letter) which provided comments on the 25 February 2005 Work Plan for <br /> Soil Vapor Assessment(Work Plan). <br /> The Response to Comments is inadequate. Regional Board staff requested a revised work plan, <br /> not responses to comments. Furthermore, the Response to Comments does not address the <br /> comments submitted by Golden State Environmental (GSE) on behalf of the RDA or comments <br /> provided by the Human and Ecological Risk Division(HERD) of the Department of Toxic <br /> Substances Control (DTSC). The following are detailed comments on the responses that the <br /> L&M OU did provide: <br /> 1. The proposed monitoring points on the undeveloped portion ofL&M OU are inadequate <br /> for completion of the health risk assessment(HRA) for the Delta View Apartments. The <br /> response to Comment#1 does not discuss which wells the L&M OU will monitor and <br /> how those wells will be monitored. Measuring volatile organic compounds and semi- <br /> volatile organic compounds from groundwater monitoring wells is an inadequate <br /> substitution for measuring soil gas concentrations from dedicated soil gas probes. The <br /> L&M OU must discuss how these samples will be adequate for evaluation of the soil <br /> vapor extraction system. <br /> 2. The response to Comment#5 is that the L&M OU will not include the collection of soil <br /> gas samples for polynuclear aromatic hydrocarbons (PAHs)because they are semi- <br /> volatile"and not likely to be present in soil gas, especially in high quantities." This <br /> statement cannot be supported without collecting the PAH data. Furthermore, the San <br /> California Environmental Protection Agency <br /> rZa Recycled Paper <br />