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PUBLICIJEALTH SER ICES <br /> O.p4U IN•..0 <br /> SAN JOAQUIN COUNTY <br /> ENVIRONMENTAL HEALTH DIVISION a <br /> Ernest M. Fujimoto, M. D., M.P.H., Acting Health Offic , <br /> 304 E. Weber Ave., Third Floor • P. O. Box 388 • Stockton, CA 2 3 D <br /> 209/468-3420 <br /> KYLE CHRISTIE MED JUN 2 5 1996 <br /> ARCO PRODUCTS COMPANY <br /> P O BOX 612530 <br /> SAN JOSE CA 95161 <br /> RE: Arco#2168 SITE CODE 1056 <br /> 441 W. Charter Way <br /> Stockton, CA 95206 <br /> San Joaquin County Public Health Services, Environmental Health Division (PHS-EHD) has reviewed the <br /> June 19, 1996"Work Plan to Conduct an Additional Subsurface Investigation" submitted by EMCON and <br /> has the following comments. <br /> Although soil samples from proposed vapor wells VW-12 and VW-13 will be investigating previously <br /> unknown areas of contamination discovered during the recent tank and line removals, PHS-EHD is <br /> concerned that ARCO may be anticipating utilizing the existing and proposed vapor wells in a full <br /> remediative effort without conducting the minimum requirements under the Corrective Action <br /> Requirements of the Underground Storage Tank Regulations (UST)(California Code of Regulations, Title <br /> 23, Division 3, Chapter 16, Article 11). <br /> Pursuant to Section 2725 (f)(2)of the Underground Storage Tank Regulations/Corrective Action <br /> Requirements, sites where the unauthorized release affects or threatens waters with current or potential <br /> beneficial uses, a feasibility study shall identify and evaluate at least two alternatives for restoring or <br /> protecting the beneficial uses. The Problem Assessment Report submitted in June 1994 evaluated only <br /> vapor extraction and did not offer another alternative for comparison. <br /> Prior to effecting any full remediation plan, a complete Feasibility Study that compares at least two <br /> alternatives should be submitted to PHS-EHD for review and evaluation. The Plan should include all the <br /> expected costs, additional wells and equipment needed, and the total time needed for each alternatives to <br /> complete its task. <br /> PHS-EHD highly recommends that all work-plans be submitted to the State Water Resources Control <br /> Board/UST Clean Up Fund Program for pre-approval. Sites anticipating reimbursement from the Clean <br /> Up Fund will find work-plan pre-approval very important and helpful. <br /> Extensive soil contamination noted in the tank pit and island area at the time of removal suggests that the <br /> groundwater below this site could have been impacted from these sources. Further vertical delineation of <br /> the extent of soil contamination in these areas is needed, and PHS-EHD will require soil sampling from <br /> proposed vapor wells VW-11 and 12. Please modify your work plan so that additional soil samples are <br /> collected and analyzed from at least 20 feet below ground surface to the groundwater interface and <br /> possibly beyond. Please include soil analysis for MTBE in this phase of work. <br /> A Division of San Joaquin County Health Care Services <br />