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i <br /> ENVIRONMENTAL HEALTH DEPARTMENT <br /> SAN JOAQUIN 'COUNTY <br /> �,•,�,.� �.o� Unit Supervisors <br /> ''1 a Donna K.Heran,R.E.H.S. " Carl Borgman,R.E.H.S. <br /> y; .,, 304 East Weber Avenue, Third Floor <br /> r. <br /> s Director " Mike Huggins,R.E.H.S.,R.D.I. <br /> Al Olsen,R.E.H.S. Stockton, California ;,95202-2708 Douglas W.Wilson,R.E.H.S, <br /> • ca.—=NSP• Program Manager Telephone: (209) 468-3420 Margaret Lagorio,R.E.H.S. <br /> < <br /> } <FOR Laurie A.Cotulla,R.E.H.S. Robert McClellon,R.E.H.S. <br /> Program Manager Fax: (209) 464-0138, Mark Barcellos,R.E.H.S. <br /> r. <br /> JOE J 1 ACHADO JUN 3 2003 <br /> 24916 S MANTECA RD <br /> MANTECA CA 95336 FFILE COPY <br /> i, <br /> a <br /> RE: Septic System-Drug Lab (UIC) Site Code: PR#0521730 <br /> 1 20333/20329 S. Airport Way <br /> Manteca, CA. 95336 <br /> San Joaquin County Environmental Health Departinent (EHD) has reviewed <br /> Limited Site Assessment Work Plan (Septic Tank Area) dated June 6, 2003 <br /> submitted by your consultant, Advanced GeoEnviro'nmental (AGE) On June 10, <br /> 2003 and has the following comments. <br /> The proposal is for soil and, if encountered, groundwat&sampling under and <br /> near the domestic septic tank, distribution box, and.,leacl'i' lines at the above <br /> referenced property in response to drug lab waste being 'placed into the septic <br /> system. <br /> Since details of the septic system's construction are unknown, AGE will <br /> excavate, but not disturb, areas near the system to'�,verify depths, location, and <br /> condition of the system. EHD will inspect the interior of the tank to determine if it <br /> can continue to be used. Cracks and other conditions that allow leakage will be <br /> required to be repaired so that the tank is watertight. <br /> i The Environmental Protection Agency (EPA) Region 9 Guidelines for Closure of <br /> Shallow Disposal Wells, 1992 states "soil.samples dray be taken at either end of <br /> the tank at a depth that is at least as deep at the bottom of the tank and must <br /> also be taken along every twenty feet of drainfreld or leaehfreld and sent to a <br /> certified laboratory for analysis." ACEs proposal to only 'submit "selected <br /> samples" for laboratory analysis does not conform to the1 investigative guidelines. <br /> EHD will require all of the soil samples collected to'be submitted for analysis. <br /> Chemical detections in soil samples from 1'-2' below the°septic system <br /> components are to be laterally and vertically defined and evaluated for <br /> remediation requirements before the system can be put back in service. The <br /> EPA requires Toxicity Characteristic Leaching Procedures (TCLP) evaluation for <br /> 1 residual contamination that is detected under septic systems. Please ensure this <br /> I' requirement is addressed should laboratory finding's indicate drug lab wastes <br /> placed in the septic tank have impacted the soil. <br />