SITE INFORMATION AND CORRESPONDENCE

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San Joaquin County DIRECTOR O� oPo. ...N Environmental Health Department Donna Heron,REHS ASSISTANT DIRECTOR r` r� 600 East Main Street Laurie Cotulla, REHS (Zmlll r� l Stockton, California 95202-3029 PROGRAM COORDINATORS f l ,` Carl Borgman, REHS • Mike Huggins, REHS,RDI Website: www.sjgov.org/ehd Margaret Laorio, REHS ��FOR Phone: (209) 468-3420 Robert McClellan, REHS Fax: (209) 464-0138 Jeff Carruesco,REHS, RDI Kasey Foley, REHS November 24, 2008 Catherine Kahler JM Equipment Cc Inc. 819 S. 9 H St. Modesto, CA 95351 Subject: JM Equipment RO#: 297 1245 W. Charter Way CUF#: 12607 Stockton, CA. 95206 Geotracker ID#: T0607700794 A meeting was held on September 17, 2008, at the office of the San Joaquin County Environmental Health Department (EHD) to discuss the Feasibility Study Report (FS) dated August 22, 2008, that was submitted by your consultant, Geological Technics Inc. (GTI) and received on Geotracker on August 25, 2008. Attending the meeting were, Margaret Lagorio, Nuel Henderson, and Michael Infurna of the EHD, Raymond Kablanow and Matt Spielmann of GTI, James Barton of the Central Valley Regional Water Quality Control Board (CVRWQCB), Paul Gill of X-19 Biological, and yourself. Discussions at the meeting included GTI's conclusion in the FS that the most cost- effective and feasible remedial action alternative for this site was the removal of four monitoring wells, soil over-excavation and removal, adding X-19 at the bottom of the 24 foot deep excavation's imported backfill, and replacing three monitoring wells. The EHD was concerned that a proposal to remove approximately 1200 cubic yards from the site and transport it offsite to a treatment facility may not be cost-effective and the State Water Resources Control Board (SWRCB) Clean Up Fund (CUF) may not reimburse the costs of the action. The EHD commented that the data for the contaminant concentrations of the petroleum impacted soil is dated and recommended that an additional soil investigation to better characterize the extent and mass of the soil plume be performed. A work plan to investigate the current lateral and vertical extents of the soil contamination should be submitted to the EHD. It was discussed that reducing the amount of soil to be removed may be more cost-effective and more likely to be reimbursed by the CUF. Additionally, it was discussed that the EHD is not familiar with the additive, X-19, you proposed to add to the excavation at the groundwater/vadose interface. Please provide the EHD with copies of letters from regulatory agencies within California that approved the use of X-19 at underground storage tank (UST) sites. Also, Mr. Barton of the CVRWQCB stated that prior to the addition of X-19 into the excavation, a bench scale test (BST) is required to test for waste discharge requirements (WDR). If it is your intention is to use X-19 in the excavation, please submit a proposal for a BST to the EHD.