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i <br /> *y PUBLIC IEALTH SERVICES <br /> SAN JOAQUIN COUNTY <br /> ENVIRONMENTAL HEALTH DIVISION <br /> Ernest M. Fujimoto, M.D., M.P.H., Acting Health Officer <br /> 445 N. San Joaquin Street • P.O. x • <br /> J q Bo 388 Stockton CA 95201-038 <br /> (2 09) 468-3420 <br /> cop , i <br /> it <br /> BREI T HUNTER i <br /> CHEVRON USA FEB 2 8 1995 <br /> PO BOX 5004 <br /> SAN RAMON, CA 94583-0804 <br /> i <br /> Re: 45 East Harding Way <br /> Stockton CA 95204 <br /> San Joaquin County, Public Health Services, Environmental Health Division (PHS/EHD) j <br /> has completed review of your correspondence dated January 30, 1995 and (February <br /> 21, 1995 which accompanied the Groundwater Technology's "Work Plan forAdditional <br /> Soil Assessment" dated February 14, 1995. PHS/EHD has prepared the following l <br /> comments for your consideration. <br /> Your correspondence dated January 30, 1995 incorrectly summarized "several <br /> telephone conversations" by indicating that should additional data demonstrate than, <br /> residual hydrocarbons pose no immediate or potential threat to groundwater quality) <br /> then PHS/EHD would issue a statement indicating that no further remediatioh would <br /> be required. Please be aware that in order to evaluate remedial alternatives'for soil <br /> and groundwater contamination, PHS/EHD did indicate that the mass of remaining <br /> hydrocarbon contamination in the soil should be estimated and the threat to; !I <br /> groundwater evaluated. However, under no circumstances did PHS/EHD agree ree to 9 <br /> prepare a statement indicating that no further remediation was required. PHS/EHD <br /> has repeatedly stated to you that according to current and potential beneficial uses of <br /> the groundwater that the groundwater contamination which has been documented on <br /> and off site requires remediation., <br /> I <br /> You also indicated that soil samples obtained during a proposed investigation would <br /> be used to screen samples for additional leaching analyses by the Toxicity <br /> Characteristic Leaching Procedure (TCLP). The work plan submitted simply°stated <br /> that EPA methods 8020 and 8015 modified would be used to analyze selected soil <br /> samples. PHS/EHD agrees that the soil borings will be located to define further the <br /> extent of contamination and that some of this information may be used to better <br /> estimate the boundaries of soil contamination. However, the results of the soil <br /> analysis may not be used to solely determine the potential threat which the residual l <br /> soil contamination poses. Since the vapor extraction was halted significant soil <br /> contamination has been evidenced. All soil samples should be used to evaluate <br /> remedial alternatives. <br /> " t <br /> ,i <br /> I4 <br /> A Division of San Joaquin County Health Care Services <br />