SITE INFORMATION AND CORRESPONDENCE

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PUBLIC-i-JEALTH SERVICES SAN JOAQUIN COUNTY ENVIRONMENTAL HEALTH DIVISION Ernest M. Fujimoto, M. D., M.P.H., Acting Health OffIFF o r 304 E. Weber Ave., Third Floor • P. O. Box 388 • Stockton, CA 95201-0388 °4�;FORa`P DR A R GLOVER 209/468-3420 MAILED MAR 181996 FAYETTE MANUFACTURING PO BOX 61 TRACY CA 95378 RE: WORKPLAN REVIEW,7675 WEST ELEVENTH ST.,TRACY SITE CODE: 2233 San Joaquin County Public Health Services Environmental Health Division(PHS/EHD) Site Mitigation staff have recently reviewed the Workplan for Additional Subsurface Investigation prepared by Smith Environmental Technologies Corporation(SETC)and provides the following comments and directives. In an effort to cost effectively characterize Leaking Underground Fuel Tank sites (LUFT's)PHS/EHD recommends the following amendments for consideration. When implemented this approach may provide significant and comprehensive contemporary data for decision making processes regarding health risk and contaminant fate and transport modeling assessments, remediation alternatives including the potential for natural attenuation, and ultimately,timely site closure certification. Conceptually, PHS/EHD concurs with SETC proposals for soil boring locations. PHS/EHD will require one soil boring in the original tank pit area, preferably in a downgradient position through native soil to obtain the geotechnical and chemical information discussed below. Additional geotechnical analyses should be included to refine the definition of vadose, capillary fringe, and saturated zone characteristics at this site. These analyses should include falling head permeability, %moisture, porosity, dry bulk density, soil pH, % organic content and C:N:P ratios for selected significantly different lithological units encountered while boring. It is recognized that a multitude of the analyses may be obtained through single tests substantially reducing the overall cost. Contractors should be chosen for field investigative activities which have the capacity to obtain field screening information in the form of soil gas analyses including soil oxygen levels and VOC empirical data potentially providing crucial information for subsequent soil boring locations within the same mobilization event. Conceptually, PHS/EHD concurs with SETC proposals for Fuel Hydrocarbon Constituent (FHC's) analyses. However, additional soil and groundwater chemical analyses is required. These analyses must include Methyl Tertiary Butyl Ether(MTBE) analysis, the current method recommendation is 8020 with an 8260 confirmation for all preliminary MTBE detection's in order to eliminate the potential for false positives. This scenario is also required for all monitoring wells on site until it is determined that this FHC oxygenate is not present at the site. PHS/EHD takes this opportunity to remind responsible parties and consultants involved at the site to continue quarterly groundwater monitoring until otherwise notified. PHS/EHD will also require a well survey including construction details for all wells in the vicinity and a general health risk assessment which may reveal any receptors to be potentially impacted during assessment or remediation activities. The general risk assessment should include potential preferential contaminant migration pathways (underground utility trenches), potential recharge areas (canals, surface water collection basins) and similar parameters. PHS/EHD has discussed this approach with Underground Storage Tank.Cleanup Fund Program (USTCFP) staff (George Lockwood) in detail and takes this opportunity to inform all responsible parties and consultants to utilize the bid process in order to contain costs and seek preapproval for site funding after receiving approval at the local level(PHS/EHD approval) and prior to engaging in site activities to avoid jeopardizing reimbursement. A Division of San Joaquin County Health Care Services