Laserfiche WebLink
(�ON <br /> SERV`�CESPUBLIC hEALTH <br /> SAN JOAQUIN COUNTY r. y <br /> ENVIRONMENTAL HEALTH DIVISION y: <br /> M. D. M.P.H. Acting Health Officer <br /> Ernest M. Fujimoto, , �... fit. <br /> 304 E. Weber Ave., Third Floor • P. O. Box 388 * Stockton, CA20�in)� fFo � <br /> 209/468-3420 <br /> MAILED :SAN 2 51996 <br /> JOHN WEBER - <br /> C M WEBER ENTERPRISES INC <br /> 3757 COLLEGE AVE <br /> SACRAMENTO CA 95818 <br /> SITE CODE: 2436 <br /> RE: Weber Point <br /> 141 North El Dorado Ave <br /> Stockton CA 95202 <br /> San Joaquin County Public Health Services, Environmental Health Division (PHS/EHD) has <br /> completed review of Fugro's "Request for Case Closure" dated December 20, 1995. PHS/EHD has <br /> prepared the following comments for your consideration. <br /> PHS/EHD has provided on numerous occasions regulatory directives to proceed with confirmation <br /> soil sampling and to discontinue the groundwater extraction systems, which PHS/EHD has <br /> consistently maintained was not an effective remedial alternative. PHS/EHD further reiterates that <br /> confirmation soil borings are necessary to demonstrate that the soil vapor extraction system <br /> remediated soil which when last characterized continued to pose a threat to groundwater. <br /> The reference to recent regulatory communications was not cited; therefore, PHS/EHD is unable to <br /> comment on the communications' applicability. PHS/EHD assumes that the technical publications <br /> cited included A Practical Approach to Evaluating Natural Attenuation of Contaminants In <br /> Groundwater (McAllister and Chang 1994) and Recommendations to Improve the Cleanu Process for <br /> California's Leaking Underground Fuel Tanks (Rice 1995). PHS/EHD has reviewed both documents <br /> and concurs that the McAllister and Chang published article provides technical information which is <br /> valuable when evaluating natural attenuation. The McAllister and Chang article relates to <br /> groundwater contamination rather than residual soil contamination. Factors recommended to <br /> demonstrate natural attenuation include a monitoring well system which defines the vertical and <br /> horizontal extent of the plume and considerable monitoring data to demonstrate its effectiveness. <br /> Simply proposing to discontinue air sparging, which enhances biological degradation, does not <br /> acknowledge the authors' conclusions and recommendations. <br /> Also, Shell Oil Company and Fugro must certainly be aware of the controversial and non-technical <br /> material which was included in the Recommendations to IMprove the Cleanul2 Process for California's <br /> Leaking Underground Fuel Tanks which was neither reviewed by technical peers or the public. For <br /> your information, it is PHSIEHD's understanding that the State Water Resources Control Board will <br /> provide the public an opportunity to comment on the comments and findings of the report which may <br /> provide technical validation of the conclusions which were presented. Also, please be aware that in <br /> no way does this report suggest that monitoring and characterization of residual contamination are not <br /> necessary to demonstrate that passive bioremediation is a effective remedial alternative. <br /> A Division of San Joaquin County Health Care Services <br />