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PUBLIC 4-,,, IEALTH SERN%4CES PaUl� <br /> SAN JOAQUIN COUNTY <br /> ENVIRONMENTAL HEALTH DIVISION < <br /> Ernest M. Fujimoto, M. D., M.P.H., Acting Health Officer <br /> 304 East Weber Avenue, Third Floor • Stockton, CA 95202 t `� <br /> 2091468-3420 C (D <br /> DALE STEELE MAY 15 199 <br /> CALTRANS <br /> PO BOX 2048 <br /> STOCKTON CA 95201 <br /> Re: Caltrans Shop 10 Site Code: 1018 <br /> 1603 South 'B" Street <br /> Stockton CA 95205 <br /> San Joaquin County, Public Health Services, Environmental Health Division (PHSIEHD) has completed <br /> review of the following reports which were recently received: <br /> Groundwater Monitoring Report-Third Quarter 1996 dated August 1996; <br /> Groundwater Monitoring Report- Fourth Quarter 1996 dated November 1996; and <br /> Problem Assessment Report and Corrective Action Plan dated December 1996. <br /> PHSIEHD has prepared the following comments for your consideration. <br /> Groundwater monitoring reports must be submitted quarterly so that PHSIEHD can evaluate and respond <br /> to information that may reflect site changes. As PHSIEHD has indicated on a number of occasions, <br /> PHSIEHD must be notified prior to any field activity. <br /> The analytical results of the July 2 and 3, 1996 and October 23 and 24, 1996 groundwater sampling <br /> events continued to evidence significant concentrations of petroleum hydrocarbon contaminants in the <br /> groundwater. The groundwater sample collected from VW1 was analyzed for methyl tertiary butyl ether <br /> (MTBE) using EPA Method 8020 and 8260; however, the 8260 analysis results did not confirm the MTBE <br /> detection that had been indicated by the 8020 analysis. The 8260 result requires confirmation and <br /> additionally the chromatographic peaks which were previously identified and quantitated as MTBE require <br /> further evaluation. There have been other additives besides MTBE which have been used to affect fuel <br /> efficiency. <br /> Please note that all but one of the existing groundwater monitoring wells are screened between 65 and 90 <br /> feet below ground surface (bgs) and the most currently reported groundwater is approximately 60 feet <br /> bgs. It is generally thought that that samples are diluted when collected from wells with submerged <br /> screened intervals or from wells with screens of greater than 20 feet in length. <br /> The corrective action plan (CAP)which was submitted failed to fulfill the criteria stated in the California <br /> Code of Regulations, Title 23, Division 3, Chapter 16 12725(d). The CAP failed to include the potential <br /> migration in water, soil, and air of the contaminants. The CAP failed to evaluate alternatives to restore <br /> and protect the potential beneficial uses of the groundwater that have been affected by the release. The <br /> CAP failed to include cleanup levels for groundwater and to propose at least two alternative to achieve <br /> numerical objectives which have been designated in the Central Valley Regional Water Quality Control <br /> Plan. The CAP failed to demonstrate that the selected alternative was the most cost effective alternative <br /> and to propose how its effectiveness will be adequately monitored. <br /> A Division of San Joaquin County Health Care Services <br />