SITE INFORMATION AND CORRESPONDENCE_FILE 1

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PUBLIC HEALTH SERVICES SAN JOAQUIN COUNTY ENVIRONMENTAL HEALTH DIVISION . Karen Furst, M.D., M.P.H., Health Officer 304 East Weber Avenue, Third Floor - Stockton, CA 95202 209/468-3420 THOMAS O'NEILL & ANDREW HYDUKE JUN 14 1999 PO BOX 923 STOCKTON CA 95201 RE: Valley Motors SITE CODE: 1166 800 E. Main St. Stockton,CA., 95202 San Joaquin County Public Health Services, Environmental Health Division (PHS-EHD) has reviewed the "Work Plan for Off-Site Assessment and Feasibility Testing" submitted by Upgradient Environmental Consultants on May 20, 1999 and has the following comments. The placement for the four additional groundwater monitoring wells off-site is approved. City of Stockton encroachment and revocable permits and the PHS-EHD well boring permit applications and$89 permit fee each are now required. Monitoring wells shall not have screened intervals longer than 20 feet. Selected soil samples (to be discussed with PHS-EHD) and all groundwater samples are to be analyzed for all seven oxygenates by EPA Method 8260B, in addition to the other analyses noted in the work plan. PHS-EHD is familiar with the success soil vapor extraction (SVE) and groundwater air sparging (AS) has had in this area and considers this alternative to be historically very cost-effective. PHS- EHD considers soil vapor extraction and groundwater air sparging as one remedial alternative for underground storage tank(UST) sites with both groundwater and soil contamination present. Placement of the minimum number of SVE and AS wells is approved. These wells should be placed in areas where they will be used in case this alternative is proven to be the most cost-effective alternative approved by PHS-EHD. In order to fully evaluate the other remedial alternative, "In-situ Enhanced Bioremediation" (ISEB), PHS-EHD will require information from other sites that have proven that this procedure was successful, feasible, and cost-effective. Data should be submitted that compares original costs, materials, and time schedules against the final outcome of the remedial effort. Any regulatory correspondence that supports this proposal and details the requirements needed to support and maintain their uses are to be submitted also. PHS-EHD is concerned with the need for multiple soil borings that may be needed to confirm the effectiveness during the injection process and minimum controls that may be needed to control the migration of the organism during its "life-time" in the subsurface. Without the above noted information for ISEB, PHS-EHD cannot approve it as a remedial alternative at this time. You may want to have your consultant consider another remedial alternative in case the use of ISEB is not supported by data so that the "two alternative methods" requirement can be met. A Division of San Joaquin County Health Care Services