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San Joaquin County DIRECTOR <br /> o U--IN <br /> Donna Herah,REHS <br /> 7-C' Environmental Health Department ASSISTANT DIRECTOR <br /> '2 600 East Main Street Laurie Cotulla, REHS <br /> Stockton, California 95202-3029 PROGRAM COORDINATORS <br /> • Carl Borgman, REHS <br /> C•9��Fo•R�.iP Mike Huggins, REHS,RDI <br /> Website: www.sJov.of/ehd Margaret Lagorio,REHS <br /> Phone: (209)468-3420 Robert McClellon,REHS <br /> Fax: (209)464-0138 ,teff Carruesco, REHS, RDI <br /> Kasey Foley, REHS <br /> 10 March 2008 <br /> Jerry Moore <br /> Moore Petroleum <br /> 885 Portofino Drive <br /> Brentwood CA 94513-6539 <br /> Subject: Moore Petroleum Bulk Plant <br /> 5491 F Street <br /> Banta CA 95304 <br /> The San Joaquin County Environmental Health Department (EHD) has received and <br /> reviewed Additional Information for Motor Oil Delineation (AIMOD) dated 29 June <br /> 2007, prepared by Apex Envirotech, Inc. (AEI) on your behalf. AIMOD was prepared <br /> in response to comments made by the EHD by letter dated 23 May 2007 regarding <br /> Motor Oil Delineation Letter, dated 16 May 2007, which had also been prepared by <br /> AEI. <br /> In AIMOD, AEI reported that from approximately 1950 to 1980 above ground tanks <br /> were utilized on the site to store weed oil and so proposed to collect a groundwater <br /> sample at 30 feet below surface grade (bsg) near cone penetration testing (CPT) <br /> boring CPT-2 to analyze for constituents utilized in the formulation of weed oil. <br /> Specifically, AEI proposes to analyze the sample for dinitro amyl phenol (DAP) and <br /> dinitro butyl phenol (DBP) by EPA Method 8270, 2-sec,4-butyl dinitrophenol <br /> (dinoseb) by EPA Method 8151 and pentachlorophenol (PCP) by EPA Method 8270, <br /> in addition to the analytical regimen currently in place for the groundwater monitoring <br /> events. AEI also proposed to install monitoring well MW-15 to the originally proposed <br /> total depth of 20 feet bsg. You may proceed with installation of MW-15 as originally <br /> proposed and approved upon obtaining the needed access agreement and permit. <br /> Intuitively, the EHD believes the proposed collection and analysis of a grab water <br /> sample near CPT-2 to determine the likely source of the analytes quantified as total <br /> petroleum hydrocarbons as motor oil (TPH-mo) is a good idea, and to increase the <br /> likelihood of success, recommends that a second sample be collected from the 42- <br /> foot depth where groundwater was also impacted by the TPH-mo in CPT-2. <br /> Before giving final approval for this scope of work, the EHD needs some additional <br /> information to evaluate the adequacy of the proposal, specifically: <br /> WP Comment Letter 0308 <br />