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{ ENVIRONMENTAL HEALTH DEPARTMENT <br /> O.P�U!N"C SAN JOAQUIN COUNTY <br /> Unit Supervisors <br /> Donna K.Heran,R.E.H.S. Carl Bergman,R.E.H.S. <br /> Director 304 East Weber Avenue, Third Floor Mike Huggins,R.E.H.S.,R.D.I. <br /> Al Olsen,R.E.H.S. Stockton, g <br /> kCalifornia 95202-2708 Douglas W.Wilson,R.E.H.S. <br /> .p Program Manager Telephone: (209) 468-3420 Margaret Lagorio,R.E.H.S. <br /> C91F O RN\ Laurie A.Corolla,R.E.H.S. Robert McClellon,R.E.H.S. <br /> i Program Manager Fax: (209)464'0138 Mark Barcellos,R.E.H.S. <br /> APR 3 0 2003 <br /> ELROY COX / COX & COX <br /> PO BOX 1046 <br /> TRACY CA 95376 <br /> +RE: Ed's Muffler Shop Site Code: 1933 <br /> 595 E. 111h Street RO#000213 <br /> Tracy, CA., 95736 <br /> San Joaquin County Environmental Health Department (EHD) has reviewed <br /> Corrective Action Plan (CAP) for Mr. Ed's Muffler(Cox & Cox) dated March 27, <br /> 2003 as submitted by Wright Environmental Services (WES) on April 3, 2003 and <br /> has the following comments. <br /> Since the current levels of Total Petroleum Hydrocarbons as Gasoline (TPHg @ <br /> c 290,000 lag/I in the groundwater) are the highest that have ever been detected at <br /> this site and there has been free product present in MW-3 and MW-9 since July <br /> ± 2001, EHD reiterates it's requirement for you quickly evaluate and enact the most <br /> cost-effective and feasible corrective action. , <br /> This CAP is the result of EHD's requirement and discussed three remedial <br /> options and costs for remediating the highly impacted groundwater. Of the three <br /> options, Soil Excavation and Removal, Soil and Groundwater Dual Phase <br /> Extraction, and In-situ Biological Degradation, your consultant chose In-situ <br /> Biological Degradation as the Corrective Action for this site. <br /> Prior to EHD concurring and approving the injection of "biologicals" into the soil <br /> and groundwater at this site, the Central Valley Regional Water Quality Control <br /> Board (CVRWQCB) has indicated that a "Report of Waste Discharge' must be <br /> submitted for their review. Their website has this report application available for <br /> your use. Additionally, you should forward the relevant laboratory information <br /> and site-specific design data proposed for this site to the CVRWQCB for <br /> evaluation. Please include data from other sites where this process has been <br /> approved, utilized, and proven successful. <br /> 1 Although an estimated cost for this option was included in the CAP, the <br /> ' estimation does not include the costs of requirements from the CVRWQCB for <br /> injection since those requirements are not known. There is one UST site in San <br /> Joaquin County where in-situ microbe injection was performed and remediation <br /> is still occurring with CVRWQCB requirements satisfied. EHD cannot approve <br /> the CAP until all requirements are known and the costs evaluated. <br />