SITE INFORMATION AND CORRESPONDENCE

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r S u]'N'PUBMAEY SAN JOAQUIN COUNTY ENVIRONMENTAL HEALTH DIVISION �q. a�P Karen Furst, M.D., M.P.H., Health Officer c«o�. 304 East Weber Avenue, Third Floor • Stockton, CA 95202 2091468-3420 FILE CO JOHN GEMELOS JUN 20 456 HOLLYWOOD AVE TRACY CA 95376 RE: Paladine Mileage Center SITE CODE: 1412 2421 Holly Dr. RO#: 0000254 Tracy, CA., 95736 San Joaquin County Public Health Services, Environmental Health Division (PHS-EHD) has reviewed the "Addendum to Closure Summary Report" dated May 3, 2001 as submitted by ATC-Associates on May 4, 2001 and has the following comments. The photographs (Figure 9) submitted in support of the product line removal are acceptable. No further investigation for the underground storage tank (UST) removal is required at this time. The data and supporting arguments submitted in support of"No Further Action" complete the majority of the requirements to evaluate your request. However, some additional investigation is required because several data gaps currently exist in the site investigation. You did not define the lateral and vertical extent of the contamination either in the soil or in the groundwater in the immediate area of the removed USTs (pit). You did not submit soil samples for laboratory analysis, even though the boring logs clearly note "strong hydrocarbon odor," nor did you install additional soil borings to define the vertical and lateral extent of soil contamination. You did not collect groundwater samples for analysis from the existing monitoring wells on a quarterly basis, nor did you install additional monitoring wells to define the vertical and lateral extent of groundwater contamination. Of particular concern to PHS-EHD is your failure to conduct quarterly sampling and reporting of the groundwater analytical results since the monitoring wells were installed in July 1996. Since that time there have only been four sampling and reporting events (only once per year, and none in 1999). As a result, it is not possible for PHS-EHD to determine the cause for the rapid decline in petroleum hydrocarbon concentrations in the groundwater, nor has your consultant offered any explanation as to the reason for the decline. Additionally, the reports that you have submitted have had an unnecessarily long time gap between the sampling event and the report submittal date. Specifically, the last groundwater sampling event was held on March 29, 2000 and the report was not submitted to PHS-EHD until July 23, 2000. This time period is excessive and does not provide PHS-EHD with a recent or complete evaluation of the groundwater quality at the site. Without current groundwater data PHS-EHD cannot evaluate your request for closure. A Division of San Joaquin County Health Care Services