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0 00 <br />Water Boards <br />EDMUND G. BROWN JR. <br />GOVERNOR <br />MATTHEW RODRIQUEZ <br />SECRETARY FOR <br />ENVIRONMENTAL PROTECTION <br />Central Valley Regional Water Quality Control Board <br />18 May 2017 <br />Vincent Victorine George Beltker <br />J.M Equipment Company Inc. Geo Corporation <br />321 Spreckles Avenue 2306 Jackie Court <br />Manteca, CA 95336 <br /> Oakdale, CA 95361 <br />J.M. EQUIPMENT COMPANY, 1245 WEST CHARTER WAY, STOCKTON, SAN JOAQUIN <br />COUNTY, GENERAL ORDER NO. R5-2008-0149-049 <br />Central Valley Regional Water Quality Control Board (Central Valley Water Board) staff <br />reviewed the Work Plan for Shallow Soil Investigation (Work Plan), dated 28 March 2017, <br />submitted on your behalf by Ground Zero Analysis Inc. (GZA) for the J.M. Equipment <br />Company property located at 1245 West Charter Way in Stockton (Site). In the Work Plan, <br />GZA proposes advancing five (5) borings via hand auger in the vicinity of well IW-5 and <br />collecting confirmation soil samples from each boring. GZA proposes to advance each <br />boring to a total depth of 8 feet bgs and collecting soil samples at 4 and 8 feet bgs, with <br />analysis to include total petroleum hydrocarbons as gasoline (TPHg), benzene, toluene, <br />ethylbenzene, xylenes (BTEX), fuel oxygenates methyl tert butyl ether (MTBE), tert butyl <br />ether (TBA), di-isopropyl ether (DIPE), ethyl tel butyl ether (ETBE), tert amyl methyl ether <br />(TAME), 1,2-dichloroethane (1,2-DCA), and naphthalene. <br />Central Valley Water Board staff do not concur with the scope of work proposed in the Work <br />Plan at this time, and request the submittal of a Work Plan Addendum. Central Valley Water <br />Board staff have the following comments on the Work Plan: <br />1. In the Work Plan, GZA indicates that soil gas wells near the "shop" building in the <br />south of the property are not needed. GZA indicates that the Site meets LTCP Vapor <br />Intrusion criteria by Scenario 3, and cites as evidence soil borings in the vicinity with <br />TPH in the top 10 feet below 100 mg/kg, and groundwater borings in the vicinity with <br />benzene concentrations less than 1,000 ug/L (less than 50 ug/L in both GP-9 and <br />GP-13). However, these two borings are located only minimally closer to the <br />structure, and are more up-gradient from the source area as compared to the cross- <br />gradient location of MW-5, approximately 30 and 90 feet west of MW-5, respectively. <br />of MW-5, but not between MW-5 and the structure. MW-5 is approximately 19 feet <br />north of the "shop" structure, and currently contains benzene at a concentration of <br />2,800 ug/L. As depth to water in MW-5 is only approximately 13.5 feet, this area of <br />the Site does not meet LTCP Vapor Intrusion criteria, and a soil gas well is needed in <br />order to properly evaluate the risk. <br />KARL E. LONGLEY ScD, P.E., CHAIR I PAMELA C. CREEDON P.E., BCEE, EXECUTIVE OFFICER <br />11020 Sun Center Drive #200. Rancho Cordova, CA 95670 I www.waterboards.ca.gov/centralvalley <br />C) RECYCLED PAPER