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PUBLIC TiEALTH SERVICES PpU,lry <br /> SAN JOAQUIN COUNTY r: <br /> ENVIRONMENTAL HEALTH DIVISION H :� <br /> Ernest M. Fujimoto, M. D., M.P.H., Acting Health Officer ` <br /> 304 E. Weber Ave., Third Floor a R O. Box 388 • Stockton, CA 95201-0388 `4�rFp �•P <br /> 2091468-3420 (C(o ❑ <br /> SRIKANTH DASAPPA <br /> USA PETROLEUM COMPANY MNLM JUL 03 IS96 <br /> 30101 AGOURA CT#200 <br /> AGOURA HILLS CA 91301-4311 <br /> RE: USA PETROLEUM #65 <br /> SITE CODE; 1356 <br /> 2500 W LODI AVENUE <br /> LODI CA <br /> San Joaquin County Public Health Services, Environmental Health Division (PHS-EHD) <br /> has completed the review of the Remedial Action Plan Addendum #1, dated February <br /> 1996, submitted by Park Environmental, and offers the following comments for your <br /> consideration. <br /> The criteria PHS-EHD uses to determine the appropriate remedial alternative for a site <br /> can be found in the California Code of Regulations, Title 23, Division 3, Chapter 16, <br /> Article 11 (Corrective Action Regulations), Section 2725(4). Appropriate cleanup levels <br /> for petroleum sites are based on requirements found in state law and policy and, more <br /> specifically, the Water Quality Control Plan for the San Joaquin River Basin. Other <br /> impacts, such as human health protection from fire, explosion, vapor migration and <br /> accumulation are also considered. Any sensitive ecosystems that may be affected <br /> must also be evaluated and, if necessary, protected. <br /> in some cases natural attenuation is an appropriate remedial alternative for a petroleum <br /> release, but this alternative must be shown to be the most cost effective approach to <br /> achieve the appropriate cleanup level when comprehensively evaluated with any other <br /> appropriate alternative, as set forth in the Corrective Action Regulations. <br /> The addendum to the Remedial Action Plan (RAP) submitted for this site does not <br /> present sufficient information on which to base an informed decision regarding the <br /> known and probable impact of the release at the site on the groundwater system, <br /> specifically on the current and future beneficial uses of the groundwater, or on the <br /> nearby surface water body. In addition, the discussions on the costs and effectiveness <br /> of the three remedial alternatives in the addendum are not supported by physical data <br /> from the site and are therefore incomplete. <br /> A Division of San Joaquin County Health Carp Services <br />