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ARCO Products Comr%_,,_/ <br /> 1055 West Seventh Stmt <br /> Post Office Box 2570 <br /> Los Angeles, California 90051-0570 <br /> Telephone 213 486 3511 <br /> January 27, 1992 ED <br /> Laurie A. Cotulla JAN 3 1 1992 <br /> Environmental Health Division _I,41RO,H �Ii,=;vTAL HEALTH <br /> Public Health Services PERMIT/SERVICES <br /> San Joaquin County <br /> P. O. Box 2009 <br /> Stockton, CA. 95201 <br /> Re: January 9, 1992 letter to Chuck Carmel or ARCO regarding ARCO <br /> station #2133 at 2908 West Benjamin Holt Di%-- Stoc':ton, CA <br /> Dear Ms. Cotulla: <br /> work with Chuck Carmel here at the ARCO Products Company and <br /> have received a copy of your letter to Chuck dated January 9, 1992 <br /> (copy attached). I have a question in regards to item number 1 of <br /> your letter and hope you can clarify this issue for me. <br /> Item number 1 requests that all monitoring wells be tested for the <br /> presence of fecal coliform contamination. Although we plan to <br /> analyze for fecal coliform, I would like clarification of its <br /> applicability to our assessment and remediation efforts of <br /> petroleum hydrocarbons. In my opinion the absence or presence of <br /> fecal coliform bacteria has no relationship to our remedial efforts <br /> at our service station located on Benjamin Holt Drive in Stockton. <br /> Certainly I could understand the need to test for this type of <br /> contamination when dealing with groundwater supply wells however, <br /> the monitoring wells at .the subject iocation are cieariy not and <br /> never will be groundwater supply wells. Testing for fecal coliform <br /> bacteria in groundwater from all monitoring wells at this site is <br /> expected to cost on the order of $750. If this requirement is applied <br /> on a periodic basis to all monitoring wells in San Joaquin County the <br /> total cost to the responsible parties will be very substantial. <br /> recommend that groundwater monitoring and extraction wells used <br /> for purposes of corrective action be provided with an exemption for <br /> testing of fecal coliform bacteria. This exemption would then allow <br /> available monies to be applied directly to mitigating the identified <br /> problem rather than testing for an unrelated organism. I would <br /> greatly appreciate your response on this issue. My phone number is <br /> (213) 486-2256 if you prefer to call. <br /> APPC-7011-1 <br /> ARCO Products Company is a Division of AtlanticRichtieldCompany (10-88) <br />