SITE INFORMATION AND CORRESPONDENCE

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PUBLIt HEALTH SERVICES .. SAN JOAQUIN COUNTY 'L JOG[KHANNA M.D..M.P.H. Health Officer , P.O. Box 2009 a(1601 East Ha A*=Avaine)a Rodmom Catifomia 95201 (209)468-3400 py R W READE C(O 40 ROBLE COURT DG�i � 7' BI!I1tIM EY CA 94705 RE: Yellow Submarine IN REPLY REFER TO SITE CODE: 2514 140 W. Harding way Stockton, CA 95202 Saar Joaquin County Public Health Services, Environmental Health Division (PHS/EHD) has reviewed the 'Phase II Remedial investigation Results' report dated October 8, 1991, prepared by WHF Environmental Consultants, Inc. We do not concur with the recommendation for closure of this site. One round of samples has been collected from the monitoring wells. Additional sampling must be done to confirm the sample results. Temperature, electrical conductivity, and pH readings taken prior to the sampling of the wells were not provided in the report. Provide PHWEHD with the field logs which indicate the date,times and volume of extracted water as well as the above readings. Also indicate the disposition of the extracted water. Since during construction of Monitoring Well #3 grout entered the well, the validity of the information provided by this well will be decided afow PHS/EHD has inspected the weU and witnessed the measuring, purging and sampling of this well. This is the down gradient well for this site and the information from it must be valid in order for PHS/EHD to be convinced that ground water has not been impacted. The investigation and remediation of the soil at this site has not been adequately addressed. The total amount of soil excavated in the unknown fuel island and the former waste oil tank location has to be clarified. The backfill of these areas also needs clarification. The report states 80 yards of stock pile soil was sampled but does not clarify the origin of this stockpiled soil. The re-excavation work plan dated January 21, 1991 discusses two excavations which would have produced a combined total of 44S yards of soil. The amount of soil in the stock pile does not correspond to the amount of soil generated from the proposed excavations. The disposition of all the excavated soil is to be clarified. in addition the sampling of the stockpiled soil was not witnessed by PHS/EHD staff. The disposition of the stockpile will be decided once the origin has been clarified, a sampling plan has been decided, the sampling has been completed under inspection and the results have been submitted to PHS/EHD. As previously noted by WHF Environmental in a report and PHS/EHD in a letter the underground lines of the waste oil tank are still unresolved. The vertical and lateral extent of soil contamination in this area should be investigated and the lines should be removed. Soil sample results at a depth of 1S feet in the area of the former waste oil tank indicate that waste oil contamination of 3400 parts per million (ppm) exists. The report indicates that benzene, toluene, Xylene, and ethylbenzene are non-detect at this depth but lab analysis results were not provided to substantiate this statement Provide PHS/EHD with the lab analysis for these results. The methods listed on the lab analysis for oil and grease are not correct per a telephone conversation with PHS/EHD staff and Geo Analytical staff. Provide PHS/EI•ID with corrected lab analysis forms. Also in future sampling use the detection limits listed in the Tri-Regional Guidelines for oil and grease. A Nvhion of San jtfaquin Ommty Health Cwt Services