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v <br /> San Joaquin County <br /> Pp U,1N Environmental Health Department DIRECTOR <br /> Linda Turkatte,REHS <br /> 1868 East Hazelton Avenue <br /> PROGRAM COORDINATORS <br /> y. Stockton, California 95205-6232 Robert McClellon,REHS <br /> Jeff Carruesco,REHS,RDI <br /> Kasey Foley,REHS <br /> • C .. �P Website: www.sjgov.org/ehd Rodney Estrada,REHS <br /> q� FpRN Phone: (209)468-3420 <br /> Adrienne Ellsaesser,RENS <br /> Fax: (209)464-0138 <br /> March 30, 2015 <br /> Messrs. Kirk Larson, PG, and Robert Trommer, CHG <br /> State Water Resources Control Board <br /> Division of Financial Assistance <br /> 1001 1 Street <br /> Sacramento CA 95814 <br /> Subject: 821 Wilson Way S, Stockton, CA <br /> Second Annual Review Summary Report CUF Claim No. 18916 <br /> San Joaquin County Environmental Health Department (EHD) has received and reviewed the <br /> draft Second Review Summary Report - Additional Work dated February 19, 2015 from Kirk <br /> Larson and Robert Trommer of the State Water Resources Control Board (SWRCB) Cleanup <br /> Fund (CUF) for the above-referenced site. The CUF found that the site meets all Low-threat <br /> Underground Storage Tank Case Closure Policy (LTCP) criteria except for: <br /> • Completion of a conceptual site model (CSM) as the lateral extent of impacted <br /> groundwater had not been delineated; and <br /> • Groundwater Specific Criteria as the lateral extent of impacted groundwater had not <br /> been delineated. <br /> The CUF recommended that the EHD direct assessment of the extent of the plume of impacted <br /> groundwater toward the east. <br /> In December 2014, the consultant for the responsible party (RP) advanced four soil borings on <br /> the east side of S. EI Dorado Street to depths of 50 feet below surface grade (bsg), collecting <br /> soil samples from 25 feet bsg to 50 feet bsg from one boring and grab groundwater samples <br /> from 50 feet bsg from all four borings. All samples analyzed were found to contain less than <br /> detectable concentrations of the contaminants of concern, so the consultant determined that the <br /> lateral extent of impacted media had been delineated; the EHD concurs. The EHD therefore <br /> considers the CSM adequate and the Groundwater Specific Criteria met by case 1(a). <br /> The EHD accepts the CUF determination that the secondary source has been removed to the <br /> extent practicable, but notes that remediation to reduce dissolved benzene concentrations to <br /> meet LTCP criteria has been ongoing. The EHD does not agree with the CUF that the site <br /> meets the vapor intrusion criterion 2(a) by Scenario 1 as there has been no demonstration of a <br /> 30-foot bioattenuation zone with total petroleum hydrocarbons (TPH) concentrations less than <br /> 100 milligrams per kilogram (mg/kg). It has been shown that soil between 13 feet bsg and 55 <br /> feet bsg has been impacted by TPH at concentrations exceeding 100 mg/kg. This may be <br /> 2015 Second Review Summary Report CUF Claim No. 18916.doc <br />