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ENVIRONMENTAL HEALTH 16EPARTMENT { <br /> Pouiry <br /> ° . co SAN JOAQUIN COUNTY <br /> 2 �-/� 2 <br /> .+ Donna K. Heran, R.E.H.S. Program Coordinators <br /> 1 Director 304 East Weber Avenue, Third Floor Carl sorgman, R.E.H.S . <br /> Laurie A. Cotulla, R.E.H.S. Stockton, California 95202-2708 Mike Huggins, R.E.H.S., R.D.I. <br /> ey . .�—� P Assistant Director Telephone: (209) 468-3420 Margaret Lagorio, R.E.H.S . <br /> � i FOR Robert McClellan, R.E.H. S . <br /> Fax : (209) 464-0138 Jeff Carruesco, R. E.H. S. <br /> Website: www. sjgov.org/ehd/ xasey Foley, R. E.H. S. <br /> JAMES MILLS <br /> WESTREC MARINAS JAN 0 2 2007 <br /> 14900 W HIGHWAY 12 <br /> LODI CA 95242 <br /> RE : King Island Resort-UST Investigation Site Code: 1557 <br /> 11530 W . Eight Mile Rd . RO#: 309 <br /> Stockton , CA. 95219 SWRCB-CUF#: 003668 <br /> The San Joaquin County Environmental Health Department (EHD) has reviewed Site <br /> Conceptual Model (SCM) dated June 6 , 2006 and Additional Site Assessment Plan <br /> (Plan) dated June 6 , 2006 as submitted by your consultant ATC Associates Inc and has <br /> the following comments . <br /> The SCM was required by the EHD in correspondence dated April 2006 and was to <br /> include calculations of the residual contaminant mass at the site . Additionally, in phone <br /> conversations with your consultant on November 14, 2006 , it was agreed on that a <br /> technical justification for the use of ozone injection at the site would be included in an <br /> updated SCM , the sampling for TPHd would be discontinued , and that a work plan for <br /> the installation of three monitoring wells was to be submitted to the EHD within 30-days. <br /> The items agreed upon have not been submitted to the EHD. <br /> A soil mass calculation was included in the SCM that used data for TPHd and TPI-Ig that <br /> was collected July 1999. Your consultant concluded that the current mass cannot be <br /> estimated without collecting new soil data and discussions included in the SCM detailed <br /> i <br /> an additional site assessment to collect this data . <br /> l <br /> Soil iso-concentration maps included in the SCM were for TPHg , TPHd , and Benzene <br /> but not for MtBE, the major constituent of concern at this site. Please provide a <br /> comprehensive soil data table and separate iso-concentration figures for MtBE at all <br /> c <br /> depths where laboratory data has been collected . <br /> Ground water contamination was discussed in the SCM. Your consultant concluded that <br /> the downward trend in ground water petroleum concentrations strongly suggests that <br /> MtBE in ground water will approach zero within the next year. <br /> After reviewing the data, the EHD cannot agree with this statement at this time. Without <br /> the lateral and vertical extents of the MtBE defined , the fate and transport of the <br /> dissolved MtBE plume cannot be evaluated . Additional investigation is warranted . <br /> r <br />