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i <br /> San Joaquin County DIRECTOR <br /> op"U"!"' Environmental Health Department Donna Her DI RENS <br /> M ASSISTANT DIRECTOR <br /> ri 600 East Main Street Laurie Cotulla,REHS <br /> a: { Stockton, California 95202-3029 PROGRAM COORDINATORS <br /> • • Carl Borgman,REHS <br /> Website:WWW. OV.Or @hd Mike Huggins,REHS,RDI <br /> Website: <br /> qui FORM S�9 � Margaret Lagorio,REHS <br /> Phone: (209)468-3420 Robert McClellon,REHS <br /> Fax: (209)464-0138 Jeff Carruesco,REHS,RDI <br /> Kasey Foley,REHS <br /> DAVID BUCCOLO, SUPERINTENDENT NOV 2 6 2007 <br /> CENTRAL CALIFORNIA TRACTION COMPANY <br /> 2201 WEST WASHINGTON STREET #12 <br /> STOCKTON CA 95203-2942 <br /> RE: Central Calif. Traction Co. SITE CODE: 1536 <br /> 1645 Cherokee Lane <br /> Stockton CA 95205 <br /> San Joaquin County Environmental Health Department (SJC/EHD) has reviewed Additional <br /> Soil and Groundwater Investigation Work Plan (Work Plan) dated October 4, 2007, <br /> submitted on your behalf by TRC and has the following comments. <br /> Between June and December 2005, soil remediation by excavation was conducted at your <br /> site. A Remedial Action Report (Report) of this work was submitted in December 2006 by <br /> CLS Environmental Services, Inc. (CLS). According to the Report, 10,400 tons of soil were <br /> removed from the site. TRC states in the Work Plan that the only significant contamination <br /> remaining in the soil after the excavation was detected in sample WWCSF-78, collected on <br /> September 21, 2005, and therefore this is the only area that requires further investigation. <br /> SJC/EHD does not completely agree with this evaluation. <br /> TRC indicated on the provided map (Figure 4)that sample WWCSF-78 was collected from <br /> the north wall of the excavation. The Report submitted by CLS placed this sample at two <br /> different locations on two different maps. Table 2, Remedial Progress Sampling Results, <br /> submitted in the CLS Report, describes the location of WWCSF-78 as West wall-floor'. <br /> TRC did not provide an explanation of how they determined that this sample was actually <br /> collected from the north wall of the excavation and not from the west wall. <br /> The collection of one grab groundwater sample was discussed in the CLS Report, and <br /> reported on CLS Report Table 6 as being collected on July 13, 2005 from a depth of 75 feet <br /> below surface grade (bsg). Upon further review of the site file and field notes, it has <br /> become apparent that this is not the grab groundwater sample that was collected from the <br /> bottom of the excavation pit. In the early weeks of the excavation, which began on <br /> June 25, 2005, an abandoned well with what appeared to be a large cement sump on top of <br /> it was uncovered. The well was determined to be approximately 100 feet deep; Central <br /> California Traction Company personal reported that this well was previously used to pump <br /> groundwater for steam locomotives. The well was destroyed under permit and inspection <br /> on July 15, 2005. Before it was destroyed a grab groundwater sample for analysis was <br /> collected from it on July 13, 2005. The consultant who collected the sample reported <br /> verbally to SJC/EHD that the water had petroleum hydrocarbon odor and sheen. CLS did <br /> not discuss discovery and disposition of this well, or their sampling of it, in the Report. <br />