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PUBLC HEALTH SE)MCES <br /> OPgU(N' C <br /> SAN JOAQUIN COUNTY r. i <br /> ENVIRONMENTAL HEALTH DIVISION h <br /> Ernest M. Fujimoto, M.D., M.P.H., Acting Health Officer <br /> 445 N. San Joaquin Street • P. O. Box 388 • Stockton, CA 95201-0388 <br /> 209/468-3420 <br /> BRETT L HUNTER <br /> CHEVRON USA PRODUCTS CO <br /> SITE ASSESSMENT & <br /> REMEDIATION GROUP <br /> P o BOX 5004 DEC 051994 <br /> SAN RAMON CA 94583-0804 <br /> RE: Former Chevron #9-4054 SITE CODE: 1780 <br /> 2103 Country Club Blvd <br /> Stockton, CA 95201 <br /> San Joaquin County Public Health Services, Environmental Health <br /> Division (PHS-EHD) has reviewed the "Remediation Work Plan" as <br /> submitted by Terra Vac and has the following comments . <br /> Although we appreciate your willingness to start your clean up at <br /> this site, PHS'-EHD is concerned that attempts to solve a problem <br /> without completely defining the extent of the contamination is <br /> not within accepted procedures as established by Corrective <br /> Action and Underground Tank Regulations and Tri-Regional <br /> Guidelines . <br /> The current Groundwater Basin Plan has established that the <br /> shallow groundwater beneath this site is "beneficial" and as <br /> such, requires "the responsible party (to) conduct a feasibility <br /> study to evaluate alternatives for remedying or mitigating the <br /> actual or potential adverse effects of the unauthorized release. <br /> Each alternative shall be evaluated (by PHS-EHD) for cost- <br /> effectiveness, and the responsible party shall propose to <br /> implement the most cost-effective corrective action. " (Title 23 , <br /> Chapter 16, Article 11, section 2725 (f) (2) . ) <br /> PHS-EHD has witnessed favorable results in our area on sites such <br /> as this one where groundwater is rather shallow and when over- <br /> excavation has been incorporated. As an interim corrective <br /> action, over-excavation can successfully remove most secondary <br /> sources of contamination that will, or currently are, impacting <br /> groundwater. <br /> As an interim activity, over-excavation and removal of <br /> contaminated soil does not require the submittal of the <br /> feasibility and cost-effectiveness study that a Draft Remediation <br /> Plan (FRP) or Corrective Action Plan (CAP) does . <br /> In addition, a Draft FRP suggests the completion of the <br /> investigative phase of site work, which for this site, is not the <br /> A Division of San Joaquin County Heaint Care Serviees <br />