SITE INFORMATION AND CORRESPONDENCE 2002 - 2013

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FILEUEPAYLTiYDEPARTMENTENVIRONMENTAL SAN JOAQUIN COUNTY �.••_,�'•.oG Unit Supervisors Donna K.Heran,R.E.H.S. 304 East Weber Avenue, Third Floor Director Carl Borgman,R.E.H.S. Mike Huggins,R.E.H.S.,R.D.I. Al Olsen,R.E.H.S. Stockton, California 95202-2708 Douglas W.Wilson,R.E.H.S. • c ._ Pro gram Manager� .� Telephone: (209) 468-3420 Margaret Lagorio,R.E.H.S. Laurie A.Cotulla,R.E.H.S. Fax: (209) 464-0138 Robert McClellon,R.E.H.S. Program Manager Mark Barcellos,R.E.H.S. HENRY CECCHINI CECCHINI CECCHINI a GIOVANNONI JUL 092004 3000 E EIGHTEENTH ST ANTIOCH CA 94509 RE: Delta Truck (former) SITE CODE: 1800 3535 E. Cherokee Road RO#000118 Stockton, CA 95205 CUF#:8109 San Joaquin County Environmental Health Department (EHD) has reviewed the March 19, 2004 Final Remediation Plan (FRP) submitted by Advanced GeoEnvironmental Inc and has the following comments. In correspondence dated October 2001, EHD responded to your request for No Further Action and concluded that the contaminant mass of the soil and groundwater contamination should be reduced by active remediation prior to evaluating any additional request for No Further Action. EHD advised that additional investigation was required in certain areas and zones identified and detailed in that correspondence. In response to EHD requirements, Monitoring Well installation and Remediation Feasibility Testing WP dated 12 February 2002 was submitted to EHD that included monitoring well MW-7 installation to replace monitoring well UST-1 and proposed field testing of multiple remedial alternatives. EHD approved that plan on February 28, 2002. The CUF (Clean Up Fund) did not approve field-testing of multiple remedial methods and as a result, only the installation of clustered MW-7 was approved. Unfortunately, due to field conditions at the time of MW-7 installation, the upper zone monitoring well was not installed and the MtBE and DCA concerns noted by EHD in the October 2001 correspondence were not resolved. This FRP proposes soil over-excavation to 20' below grade to remove the TPH-d impacted clayey soils and the injection of Ozone into the ground water to remediate the MtBE and DCA. A FRP is typically proposed for a site that has had its soil and ground water lateral and vertical extents delineated. Additionally, prior to a site entering into a full remedial action plan, an understanding of the mass of residual contamination, its migration pathways, and a full understanding of the subsurface mechanisms that affect this mass is required. Remedial alternatives must also be evaluated for feasibility and cost-effectiveness before a site can successfully advance to the remedial phase. Although EHD understands that clayey soils with elevated levels of TPH-d do not typically respond well to soil vapor extraction or other remediation alternatives, by presenting this proposal without cost or cost comparisons EHD cannot concur with your conclusions.