SITE INFORMATION AND CORRESPONDENCE FILE 2

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ENVIRONMENTAL HEALTH DEPARTMENT SAN JOAQUIN COUNTY Unit Supervisors Donna K.Heran,R.E.H.S. Carl Borgman,R.E.H.S. A 304 East Weber Avenue, Third Floor Director 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. • �•., o Program Manager Telephone: (209) 468-3420 Margaret Lagorio,R.E.H.S. •q 4:i i F o,R c�� Laurie A.Cotulla,R.E.H.S. Fax: (209) 464-0138 Robert McClellon,R.E.H.S. Program Manager APR 2v4akllos,R.E.H.S. ED RALSTON SCOTT T HOOTON TOSCO MARKETING COMPANY BP OIL COMPANY 1380 LEAD HILL RD STE 120 295 SW 41ST ST ROSEVILLE CA 95661 RENTON WA 98055 RE: TOSCO-76/former BP#11192 SITE CODE: 1995123 1403 Country Club Blvd. RO#:0000087 Stockton, CA.,95204 San Joaquin County Environmental Health Department(EHD) has reviewed the"Corrective Action Plan" dated March 13, 2002 as submitted by Gettler-Ryan Inc(GR)on March 13, 2002 and has the following comments. As discussed and noted in past correspondence, EHD has allowed the submittal of this CAP in lieu of a Problem Assessment Report. The CAP was to include and summarize all data and findings from all of the previous investigative phases for this site as well as include supporting field-testing and data for remedial alternative feasibility. This CAP did not include the data adequate for EHD to concur that the site contamination is defined. The CAP did go on to discuss five remedial methods and their suitability at this site. Of particular concern to EHD is that Ozone Microsparging (OMS)was concluded to be the most feasible method for this site, yet no field-tested, site-specific data was presented to support this conclusion. The conclusion supporting OMS (Option#5)was based on GR statement, "Initial results of GR field tests at other sites indicate that this is a feasible remedial technique for treating WE and other petroleum compounds at this site". This conclusion is too general and not site-specific enough for EHD to accept without further tests or supporting evidence. EHD is aware of other TOSCO sites undergoing OMS at this time. All of these sites are considered to be in 'interim remediation'since no long-term data exists to show that this method has successfully reduced groundwater contamination to'pre-release' conditions. TOSCO was to submit the findings and an evaluation of the OMS effort(s)to EHD showing that this method could be the most feasible and cost- effective based on the data collected from the six-month interim period. In order to allow corrective action at this site to progress, EHD will also permit TOSCO to test OMS at this site for six months to evaluate the method for feasibility or as interim remedial action. As an alternative to the six-month test period, EHD will allow TOSCO to submit data to support the conclusion that this remedial alternative would work at this site as it has at others. Sufficient data should be submitted to allow evaluation of all necessary elements needed for OMS and support the conclusion that these sites are all similar enough for OMS to be feasible and cost-effective at the subject site. Once TOSCO has determined which option will be taken to demonstrate the feasibility of OMS, a complete CAP is to be submitted to EHD for evaluation. This updated CAP must include complete tabulated soil and groundwater data, iso-concentration maps for each constituent of concern at each depth of concern, calculations of contaminant masses, cross-sections showing the extent of the plume, sample locations and depths, and concentration data for each detected constituent, and an evaluation of 0— + r,f oath rPrnp-dini alternative listed in the evaluation.