SITE INFORMATION AND CORRESPONDENCE

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ERV,-CES U,NPUBLICHEALTH S :..� .� SAIN JOAQUIN COUNTY 0 �4 ENVIRONMENTAL HEALTH DIVISION ;. Ernest M. Fujimoto, M.D., M.P.H., Acting Health Officer �%FOR 445 N. San Joaquin Street • P.O. Box 388 • Stockton, CA 95201-0388 (209) 468-3420 _ oo � JOHN JOHNSON THE CUSTOMER COMPANY P o BOX 886 JUL 1994 BENICIA CA 94510 RE: 15 EAST GRANT LINE ROAD SITE CODE: 1404 TRACY CA San Joaquin County Public Health Services, Environmental Health Division (PHS/EHD) has completed the review of the "Remediation Workplan" dated June 13, 1994,submitted by Pacific Rim Environmental, and has the following comments for your consideration. In a letter to you from PHS/EHD dated April 28, 1994,you were directed to continue to investigate the full extent of the soil and groundwater contaminant plumes and to submit a workplan for this investigation by June 6, 1994. In a telephone conversation on June 10, 1994 between you and PHS/EHD staff,you explained that you had initiated the compilation of a proposal for site remediation using bioremediation technology that would soon be submitted to PHS/EHD for review. At that time, PHS/EHD reiterated the need for a complete assessment of the concentration and distribution of the contaminants in the soil and the groundwater at the site. Please be informed that Article it of Chapter 16,Title 23 of the California Code of Regulations governs the cleanup of petroleum releases. A copy of Article 11 is enclosed for your reference. Section 2725 discusses the need to assess the nature and vertical and lateral extent of the release so that a cost-effective method of cleanup can be determined. Section 2725(f) requires that the determination of a cleanup method be based on feasibility studies so that the most cost-effective corrective action will be chosen. These requirements were established so that the money spent to abate releases of petroleum would be used in the most efficient, cost-effective manner. Without knowing the full extent of the contaminant plume or the results of feasibility studies, any remedial option chosen may not prove to be the most efficient or the most cost effective. Because the full extent of the contamination at this site has not yet been determined, this proposal for remediation does not comply with the requirements of Article 11 of Chapter 16,Title 23 of the California Code of Regulations. However, section 2722(b) does allow a responsible party to take interim remedial actions to abate the actual or potential effects of an unauthorized release. Your proposal for bioremediation can be initiated under this section of the regulations concurrently with continued assessment investigation. However, you must be advised that by forgoing the assessment and feasibility requirements you may not be utilizing the most efficient, cost-effective remedial alternative for this site. Furthermore,you must be advised that if the interim remedial measure of bioremediation does not cleanup the release to standards established by the California State Water Resources Control Board Resolution #68-16 and #92-49 (also enclosed), you will be required to perform the necessary feasibility studies to determine if a more effective approach exists. Ultimately, the overall casts of the remediation may be increased significantly. The California State Water Resources Control Board resolution #68-16 (Statement of Policy with Respect A Oi%i.ion of San Joaquin County Health Care Service.