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San Joaquin County 14kod DIRECTORDonna Heran,REHS <br /> Environmental Health Department <br /> r ASSISTANT DIRECTOR <br /> 600 East Main Street Laurie Cotulla,REHS <br /> :. <br /> Stockton, California 95202-3029 PROGRAM COORDINATORS <br /> --__ Carl Borgman,REHS <br /> Mike Huggins,REHS,RDI <br /> 4�'FOR� Website: www.sjgov.org/ehd Margaret Lagorio,REHS <br /> Phone: (209)468-3420 Robert McClellon,REHS <br /> Fax: (209)464-0138 Jeff K seyaHS,RDI <br /> Foley, HS <br /> DAVID BUCCOLO, GENERAL MANAGER MAY 14 2007 <br /> CENTRAL CALIFORNIA TRACTION COMPANY <br /> 2201 WEST WASHINGTON STREET #12 <br /> STOCKTON CA 95203-2942 <br /> RE: Central California Traction Company SITE CODE: 1536 <br /> 1645 Cherokee Lane <br /> Stockton CA 95205 <br /> San Joaquin County Environmental Health Department(SJC/EHD) has reviewed <br /> Remedial Action.Report(Report) dated December 12, 2006, submitted on your behalf <br /> by CLS Environmental Services (CLS) and has the following comments. <br /> The Report discusses an interim remedial activity that was performed at the above <br /> referenced contaminated underground storage tank (UST)site from June through <br /> December 2005. The interim remediation was conducted per the May 16, 2005 Bohm <br /> Environmental Solutions Remedial Action Work Plan (RAWP) and.the June 20, 2005 <br /> RAH Environmental. Inc. letter containing calculations of contaminant mass remaining <br /> at the site. The proposed interim remedial activity was to excavate and remove from <br /> the site petroleum hydrocarbon impacted soil. The estimated dimensions of the <br /> proposed excavation were approximately 10x50 feet with a maximum depth of 40 feet <br /> below surface grade (bsg). In correspondence dated June 2, 2005, SJC/EHD. <br /> approved in concept the interim remedial action, noting that a feasibility study and final <br /> corrective action plan were still required. <br /> The Report states that the objective of the remediation was to remove petroleum <br /> hydrocarbon impacted soil associated with two UST's removed from the site in 1999, <br /> "and to allow for natural attenuation of any remaining sorbed and aqueous phase <br /> petroleum hydrocarbons found in the localized and shallow groundwater„. This is not <br /> an accurate statement. The RAWP stated that evaluation of site conditions "indicates <br /> that additional mitigation of the contaminants of concern by in-situ means nor the ability <br /> of the affected soil and groundwater to naturally attenuate without interference is not <br /> effectual", but made no specific proposal to use natural attenuation as a remedial <br /> method at this site, nor was any implied. The RAWP did propose the re-installation of <br /> groundwater monitoring wells previously installed at the site that had to be destroyed <br /> prior to beginning the excavation. <br /> The maps submitted with the Report indicating confirmation soil sample locations are <br /> not clear. The Report states that confirmation soil samples were collected on a 20-foot <br /> grid pattern from the floor of the excavation, but no grid pattern is apparent on any map <br /> provided, and only five soil samples are listed on Table 6, Final Remedial Confirmation <br /> Sampling Results. <br />