SITE INFORMATION AND CORRESPONDENCE

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PUBLICHEALTH SERViCES SAN JOAQUIN COUNTY ENVIRONMENTAL HEALTH DIVISION Ernest M. Fujimoto, M.D., M.P.H., Acting Health Officer 445 N. San Joaquin Street • P.O. Box 388 • Stockton, CA 95201-0388 ��iFoa�'�t► (209) 468-3420 TOM PORTELE GREYHOUND LINES INC P 0 BOX 660362 JAN 299_?. DALLAS TX 75266-0362 RE: Greyhound Terminal /#8969 SITE CODE: 1041 121 S. Center St. Stockton, CA 95201 San Joaquin County Public Health Services, Environmental Health Division (PHS-EHD) has reviewed the "Biannual Status Report, December 1993" as submitted by Engineering- Science Inc., and has the following comments. Discussions included within the report suggested that all "zero-line" determinations have been achieved. Only the groundwater aspect was discussed and there was no mention of the "zero-line" determination for the soil contamination still present on site. The last set of borings installed and sampled along the east side of the site only supplied data to support that soil at approximately 39 feet below ground surface and 45 feet below ground surface has no contamination. No data for the status of the soil to the west or at depths where other soil contamination still exists has been submitted. Further investigation is required to determine the extent of the soil contamination. The State Water Resources Control Board (SWRCB) adopted Resolution No. 92-49 "Policies and Procedures for Investigation and Cleanup and Abatement of Discharges Under Water Code Section 13304" on June 18, 1992. The Resolution states that "on or before July 1, 1992, the SWRCB shall establish policies and procedures that its representatives and the representatives of the RWQCB [Regional Water Quality Control Board] shall follow for the oversight of investigations and cleanup and abatement activities resulting from discharge of hazardous substances". The Resolution outlines in formal format, regardless of the type of discharge, procedures and policies applicable to investigations, cleanup, and abatement activities. The Resolution is currently under review by the Office of Administrative Law for language clarification, however, the Resolution is supported by both the SWRCB and the RWQCBs. Furthermore, while the title of the Tri-Regional Board Staff investigative manual might imply that the document is a recommendation, it directly reflects the intent of Resolution No. 92-49, the intent of the SWRCB, and the intent of PHS-EHD. Therefore, at a minimum, detection limits analyzing groundwater shall report the practical quantitative limits (PQLs) achievable by the laboratory. Detection limits of 0.5 ug/I (ppb) or 0.005 mg/I (ppm) are the only limits to be used for water analysis of Benzene, Toluene, Ethyl Benzene, and Xylene (BTEX) utilizing EPA method 602. Detection limits for water samples being analyzed for Total Petroleum Hydrocarbons as Diesel (TPH- D) shall be 50 ug/I (ppb) or 0.05 mg/I (ppm) utilizing EPA method 8015 modified. A Division of San Joaquin County Health Care Services