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PUBLIC HEALTH SERVICES �oP �o <br /> G <br /> SAN JOAQUIN COUNTY ?� <br /> JOGI KHANNA M.D.,M.P.H. <br /> Health Officer P <br /> oq � <br /> P.O. Box 2009 • (1601 East Hazelton Avenue) 0 Stockton, California 95201 �iFp'a� <br /> (209)468-3400 <br /> CHUCK CARMEL <br /> ARCO PRODUCTS COMPANY /�� (� <br /> P O BOX 5811 NOV 2 3 199 <br /> SAN MATEO CA 94402 J <br /> RE: Village ARCO #2133 SITE CODE. 1021 <br /> 2908 West Benjamin Holt <br /> Stockton CA 95207 <br /> San Joaquin County Public Health Services, Environmental Health Division (PHS/EHD) has completed <br /> review of the letter report which responded to the PHS/EHD request for additional soil investigation. The <br /> letter report was prepared by Brown and Caldwell and dated September 23, 1992. PHS/EHD has also <br /> completed review of the "'Third Quarter Report for 1992" prepared by Brown and Caldwell and dated <br /> November 10, 1992. <br /> The letter report requested that PHS/EHD rescind the request for further soil characterization. PHS/EHD <br /> requested, in correspondence dated August 28, 1992, that a work plan be submitted by September 30, 1992- <br /> The work plan was requested because the boundaries of soil contamination had never been established. <br /> PHS/EHD has evaluated Brown and Caldwell's responses to PHS/EHD concerns and recently presented <br /> documented results of the soil and groundwater investigation to the PHS/EHD Technical Review <br /> Committee (TRC) and to representatives of the Central Valley Regional Water Quality Control Board <br /> (CVRWQCB). PHS/EHD has the following comments, reflecting the concerns of the TRC and the <br /> CVRWQCB, for your consideration. <br /> The request to rescind the PHS/EHD request for a work plan to define the extent of soil contamination is <br /> denied. Additional investigation of the extent of soil contamination is necessary. Please prepare and <br /> submit by January 15, 1993 a work plan to address PHS/EHD requests to investigate the boundaries of <br /> soil contamination. The work plan may include the provision, if contamination is encountered, to install <br /> vapor extraction wells and/or monitoring wells. Since the area of concern is to the south, south-west, and <br /> west of the site, encroachment agreements will be necessary prior to the commencement of the <br /> investigation; therefore, negotiations should be initiated to proceed with the necessary investigation. <br /> PHS/EHD appreciates the re-evaluation of the proposed vapor extraction remediation system. The <br /> response to increase the initial number of vapor extraction wells from five to twelve wells will increase the <br /> area influenced by the proposed vapor extraction system. Please prepare and submit an application to the <br /> San Joaquin Valley Unified Air Pollution Control District for an Authority to Construct permit. Please <br /> also submit an application to the City of Stockton Community Development Department for a building <br /> permit to construct the vapor extraction system. <br /> As PHS/EHD stated in correspondence dated August 30, 1991 "It is likely that until the soil <br /> contamination of the site is addressed, the groundwater remediation system proposed and in operation will <br /> simply mask the petroleum contamination of the site." The groundwater extraction system has extracted <br /> and discharged approximately 23,000,000 gallons of groundwater since the unauthorized release of 1984. <br /> This type of remediation has not proved effective. Contaminated soil continues to remain in contact with <br /> groundwater and the contaminants continue to impact groundwater. <br /> A Division of San Joaquin County Hcatth Care Scrviccs <br />