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ENVIRONMENTALEALrI H DEPARTMENT <br /> S1',LN JOAQUIN COUNTY unit Supervisors <br /> Donna K Heran,R E H S 304 East Weber Avenue,Third Floor Carl Borgman,R E N S <br /> Director Mike Huggins,R E H S,R D 1 <br /> • Al Olsen,R E H S Stockton, California 95202-2708 Douglas W Wilson,R E H S <br /> Program Manager Telephone (209) 468-3420 Margaret Lagono,R E H S <br /> LrFOR� Laurie A Cotulls,RE H S Fax (209) 464-0138 Robert McClelion R E H S <br /> Program Manager Mark Barcellos,R E H S <br /> APR 3 0 2003 <br /> ELROY COX / COX & COX <br /> • PO BOX 1046 <br /> TRACY CA 95376 MAY 0 12001 <br /> RE Ed's Muffler Shop Site Code 1933 <br /> 595 E 'I 1 th 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 /> 290,000 µg/l 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, Sod 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 infection 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 /> 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 LIST site in San <br /> Joaquin County where in-situ microbe injection was performed and remediation <br /> 1s still occurring with CVRWQCB requirements satisfied EHD cannot approve <br /> the CAP until all requirements are known and the costs evaluated <br />