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ENVIRONMENTAL HEALTH DEPARTMENT <br /> PQuiM <br /> ° SAN JOAQUIN COUNTY <br /> z. Donna K.Heran,R.E.H.S. Unit Supervisors <br /> iX Director 304 East Weber Avenue, Third Floor Carl Borgman,R.E.H.S. <br /> AI Olsen,R.E.H.S. Stockton., California 95202-2708 Mike Huggins,R.E.H.S.,R.W. <br /> '' a • er <br /> Program Manager Douglas W.Wilson,R,E..H.S. <br /> a<;fioa` g g <br /> Laurie A.Cotulla,R.E.H.S. Tele phone: {209} 468-3420 �. , Margaret Lagorio,R.E.H.S: <br /> Program Manager Fax: (209) 464-0138 Robert McClellon,R.E.H.S. <br /> -Mark Barcellos,R.E.H.S. <br /> DAN DECKER ` <br /> CONTIGROUP COMPANIES INC H H �¢ MAY I ® ; <br /> 277 PARK AVENUE 50th FLOOR.,, <br /> NEW YORK NY 10172 <br /> U; <br /> ROBERT MENTELOS <br /> PENNY NEWMAN GRAIN x <br /> 1805 HARBOR ST . <br /> STOCKTON CA 95203 <br /> RE: CONTINENTAL GRAIN CO Site Code: 1132 <br /> r :1805 HARBOR ST <br /> STOCI{TON CA 95203 " r; <br /> San Joaquin County Environmental Health Department (EHD) has reviewed CorredmeAdion Plan; <br /> Addendum(CAT-A) dated March 2005 prepared by.Huff& Huff,Inc. (H&H). The CAP-A proposed <br /> three over-excavation alternatives: <br /> Al Excavation to 14 to 17 feet into groundwater table and laterally o monitoring well M%XI-4, <br /> removing approximately 850 cubic yards of impacted soil and 506 yards overburden; this <br /> alternative will require shoring and dewatering. ,Cost estimate: $254 Thousand (I) to 298K. <br /> A2 Excavation to 5 feet below groundwater table and laterally to MW-3,removing <br /> approximately 627 cubic yards of impacted soil and 672 yards overburden; this alternative <br /> will not requite shoring, but may require dewatering. Cost estimate: $150 K to 183K. <br /> A3 Excavation to 14 to 17 feet below groundwater table and laterally to MW-3,removing <br /> approximately 961 cubic yards of impacted soil and 672 yards overburden; this alternative <br /> will requite both shoring and dewatering. Cost estimate: $276K to 322K <br /> H&H recommended A2 as the most cost-effective alternative to remove,the source of free product. <br /> EHD does not agree with H&Iil's alternative of A2. The highest concentration of Total Petroleum <br /> Hydrocarbons as diesel (TPH-d) in a monitoring well MW2 soil sample, 14,000 milligrams per <br /> kilograms (mg/kg), vas taken at 20 feet below surface grade (bsg). Depth to groundwater of M1W2 <br /> from 1998 to 2002 was between 8 feet bsg to 412 feet bsg. _Excavating to 5 feet below water table will <br /> not address the most impacted soil near the source of contanunation in the soil at 20 feet bsg where <br /> the diesel,concentration is the highest. A2 is the.least costly but is not the most effective alternative. <br /> # A <br /> In a consultation by phone with Central Valley California Regional Water Quality Control Board <br /> (CVRWQCB) on May 3,2005,RWQCB agreed with EHD that Al is the more appropriate and . <br /> effective alternative. The TPH-d concentration of the M\X72 soil sample at 25 feet bsg was 1,500 <br /> mg/kg. The TPH-d concentrations in boring B1 soil samples (131 was located about 10.feet <br /> northwest of MW-2) were 6,800 mg/kg at 20 feet bsg, and 3 mg/kg at 25 feet bsg. The TPH-d 4 <br /> f <br />