SITE INFORMATION AND CORRESPONDENCE FILE 2

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San Joaquin County Environmental Health Department DIRECTOR Donna Heran, REHS 600 East Main Street Stockton, California 95202-3029 PROGRAM COORDINATORS } � Robert McClellon, REHS .•'' Jeff Carruesco, RENS, RDI Website: www.sjgov.org/ehd Kasey Fofey,REHS F o R Linda Turkatte, REHS Phone: (209) 468-3420 Fax: (209) 464-0138 August 17, 2011 Mr. R. Ellis, Jr. Ms. Ethyl D. Ellis, Trustee et glia 1991 West Lincoln Road Stockton, California 95207-2462 Subject: California Tank Lines, Inc. 3105 South EI Dorado Street Stockton, California 95206 Dear Mr. Ellis: The San Joaquin County Environmental Health Department (EHD) has reviewed Corrective Action Plan Feasibility Study (CAPFS), dated June 2011, prepared by Taber Consultants (Taber), on your behalf for the above-referenced site. The CAPFS was submitted in response to the EHD letter dated 01 April 2011 directing that a revised corrective action plan (CAP) be submitted that included evaluation of several methods for site remediation, and directed that contaminant mass estimates, supported by calculations, for sorbed and dissolved total petroleum hydrocarbons as gasoline (TPH-g), benzene, 1,2-dichloroethane (1,2-DCA), total petroleum hydrocarbons as diesel (TPH-d), and total petroleum hydrocarbons as motor oil (TPH-mo) be included in the CAP as well as an analysis for cost-effectiveness for the recommended remedial technologies. In the CAPFS, Taber focuses on the two areas where petroleum hydrocarbon concentrations are significant: 1) near MW-2 where TPH-d and TPH-mo have been detected as free product, and 2) near MW-4 where TPH-g; benzene, toluene, ethylbenzene and total xylenes (BTEX); di- isopropyl ether (DIPE) and 1,2-DCA have been the predominant contaminants of concern. Although Taber does not provide contaminant mass estimates for sorbed constituents, Taber estimates that approximately 55 gallons of free product remain in the area of MW-2; and approximately 11.4 pounds of TPH-g, 55.1 pounds of TPH-d, 615.6 pounds of TPH-mo, 0.3 pounds of benzene and 0.5 pounds of 1,2-DCA remain in groundwater at this site. The source of the free product is inferred to have been an unauthorized release from two former waste oil underground storage tanks (USTs) removed from the site in 1990. The source of the petroleum hydrocarbon contamination in the area of MW-4 is unknown. Taber hypothesizes that the hydrocarbon contaminant source may be from an unreported surface spill or "possibly due to a documented groundwater plume emanating from the Pacific Pride facility to the south." Taber supports the second hypothesis with the following information: