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ENVIRONMENTAL HEALT&EPARTMENT p4u N Donna K.Heran,R.E.H.S. SAN JOAQUIN COUNTY Unit Supervisors 0: Director 304 East Weber Avenue, Third Floor Carl Borgman,R.E.H.S. Al Olsen,R.E.H.S. Stockton, California 95202-2708 Mike Huggins,R.E.H.S.,R.D.I. • cq: a`c.. Program Manager Telephone: 209 Douglas W.Wilson,R.E.H.S. Foa Laurie A.Cotulla,R.E.H.S. p ( ) 468-3420 Margaret Lago Program Manager Fax: (209) 464-0138 Robert McClellon,R.E.H.S. Mark Barcellos,R.E.H.S. SEP 2 0 2005 KYLE CHRISTIE ROSE V RODGERS TRUST ETAL ARCO PRODUCTS COMPANY BILL & LORRAINE HALVORSON 6 CENTERPOINT DRIVE LPR6-161 10040 DAVIS ROAD LA PALMA CA 90623-1066 STOCKTON CA 95209 RE: Former ARCO Station No. 2168 SITE CODE: 1056 441 W. Charter Way Stockton CA 95202 San Joaquin County Environmental Health Department(SJC/EHD) has reviewed Work Plan for the Abandonment of a Groundwater Monitoring Well, Installation of an Interim Soil Vapor Extraction/Air Sparge Groundwater Treatment System, and Installation of Groundwater Monitoring Wells—Addendum (Addendum) dated September 14, 2005 and received by SJC/EHD on September 21, 2005, submitted on your behalf by URS Group, Inc. (URS) and has the following comments. In the Addendum URS proposes several changes to the previously submitted and conditionally approved work plan of the same name (Work Plan) dated June 9, 2005. SJC/EHD approval conditions to the original Work Plan were detailed in correspondence dated June 23, 2005. The Addendum proposes the destruction of eight vapor extraction wells by pressure grouting, installation of 4 instead of 3 shallow groundwater monitoring wells located on the east side of the property, installation of 22 instead of the originally proposed 21 dual completed soil vapor extraction/air sparge (SVE/AS)wells, and destruction by pressure grouting through remediation piping of the SVE/AS wells following completion of the remediation. The Addendum also presented a site map showing a different configuration of the SVE/AS well locations than was submitted in the original Work Plan, with a shift of remedial emphasis to a different portion of the property. SJC/EHD does not approve the destruction of the existing vapor extraction wells by pressure grouting. These wells were installed in documented contaminated soil, and while they have never been used as groundwater monitoring wells most of them have total depths that are currently in groundwater. These vapor wells must be destroyed by overdrilling to total depth and backfilling with neat cement grout applied through a tremmie pipe. URS has submitted via email on September 26, 2005 agreement that these wells will be destroyed by overdrilling. Please note that the site map submitted with the Addendum does not show the location of vapor wells VW-5, VW-9 or VW-12, though they are three of the wells proposed to be destroyed.