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i <br /> ENVIRONMENTAL HEALTH DEPARTMENT <br /> A UIN COUNTY <br /> o.-•.-: '�,co SAN JO Q Unit Supervisors I <br /> or man R.E.H.S. <br /> 8'-tl Donna K.Reran,R E.Hs• 304 East Weber Avenue, Third Floor <br /> Carl B g <br /> a A " < Director Mike Huggins,R.E.H.S.,R.D.I. <br /> ria , <br /> Al Olsen,R.E.H.S. Stockton, California 95202-270 Douglas W.Wilson,R.E.H.S. <br /> 'P• <br /> Program Manager Telephone: (209) 468-3420 Margaret Lagorio,R.E.H.S. <br /> Cq F O R"\ Laurie A.Cotulla;R.E.H.S. Robert McClellon,R.E.H.S. <br /> / Fax: (209) 464-0138 Mark Barcellos,R.E.H.S. <br /> Program Manager <br /> JOHNSON NOV 14 JOHN JOHNSON <br /> THE CUSTOMER COMPANY <br /> 4457 PARK ROAD <br /> BENICIA CA 94510-1124 <br /> RE: THE CUSTOMER COMPANY SITE CODE 1404 <br /> 15 EAST GRANT LINE ROAD <br /> TRACY,CALIFORNIA <br /> San Joaquin County Environmental Health Department (EHD) has reviewed Work Plan for <br /> Additional Soil Characterization, dated 10 June 2003, prepared and submitted to EHD by <br /> H?OGEOL A GroundWater Consultancy (H2OGEOL) on your behalf. This work plan was <br /> submitted in response to an EHD letter dated 11 April 2002, requesting that data be submitted <br /> that defines the lateral and vertical extent of soil contamination at this site. In the work plan; <br /> H2OGEOL proposes to advance 14 hand-auger borings to the depth of groundwater, <br /> approximately seven feet below surface grade (bsg), while collecting soil samples at 3, 5, and 7 <br /> feet bsg, for possible laboratory analyses. H2OGEOL considers these 14 borings necessary <br /> because the previous soil data, dating back to at least 1995, do not include the fuel oxygenates <br /> and lead scavengers in the soil analyses. EHD believes that this work plan, as proposed, isnot <br /> adequate or necessary for the following reasons: <br /> • EHD does not see the necessity for a soil investigation to assess fuel oxygenates and lead <br /> scavengers considering that the primary justification put forward by H2OGEOL for the 14 <br /> soil for fuel oxygenates. With only six to nine <br /> w hand-auger borin yS <br /> shallos was to assess$ <br /> feet of vadose zone, a significant release of fuel is very likely to immediately impact such <br /> shallow groundwater. Review of groundwater monitoring data shows the major methyl <br /> tertiary-butyl ether (MTBE) impact to groundwater to involve wells MW-4, MW-5, and <br /> MW-8; none of the proposed boring locations, with the possible exception of HA-2, is <br /> located in areas that seem likely to encounter soil impacted by fuel oxygenates. The <br /> generally increasing MTBE concentrations, and recent detection of tertiary-butyl alcohol <br /> (TBA) and tertiary-amyl methyl ether (TAME), leads EHD to believe there has been an <br /> on-going release from the underground storage tank system. <br /> • . Proposed hand-augered borings, HA-6 through HA-12, are located outside the area of <br /> known hydrocarbon contamination in sand and do not appear to be necessary. A <br /> justification based on historical analytical data or new information is needed to <br /> demonstrate a need for these boring locations. <br /> • Proposed hand-augered borings do not address the need for the previously directed <br /> vertical delineation of all contamination. <br /> n <br />