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%WWI <br /> P UBLIC HEALTH S <br /> ERVICES oA. ....� <br /> SAN JOAQLIN COUNTY <br /> JOG[KHANNA Nf l)..M.P.H. <br /> Health Officer <br /> P.O. Box 2009 (1601 East Hazelton Avenue) •Stockton, California 95201 <br /> (209)468-3400 <br /> CHRIS RONSON <br /> P O BOX 8 ,' <br /> ESCALON CA 95320-008 SEP J 8 1992 <br /> RE: Escalon Packers SITE CODE: 2150 <br /> 1905 McHenry Avenue <br /> Escalon, Ca <br /> San Joaquin County Public Health Services, Environmental Health Division (PHS/EHD) has completed <br /> the review of the report "Preliminary Investigation and Evaluation Report" dated July 13, 1992, submitted <br /> by Geological Audit Services, and has the following comments. <br /> The quantity of data that Geological Audit was able to gather during their assessment work given the <br /> limited access to the tank area is commendable. The data gathered from the eight soil borings has <br /> adequately defined the lateral and vertical extent of the soil contaminant plume. <br /> The report presents the lateral and vertical extent of the plume, the approximate volume of the <br /> contaminated soil and a clear description of the subsurface lithology. The recommendation in the report <br /> for no further assessment work appears to be warranted at this time. <br /> Current remediation technologies commonly used to treat contaminated soils at underground storage tank <br /> sites would not be effective or feasible given the unique restraints and conditions at this site. Therefore, <br /> the recommendation to leave the contaminated soil in place also appears to be warranted at this time. <br /> The discussion presented in the report supporting the decision to leave the contamination in place without <br /> threat to groundwater appears to be justified with the data gathered from the assessment work. <br /> However, an additional analytical test should be performed on a representative contaminated soil sample <br /> that will simulate the solubility of the contaminants to be left in place. The results of this test will give an <br /> indication as to the leachability of the contaminants and provide further justification for leaving the <br /> contaminants in place without having to monitor the groundwater in the future. <br /> The soil sample should be subjected to the extraction procedure used for the waste extraction test as <br /> described in the California Code of Regulations, Title 22, Chapter 11, Appendix II, with one modification: <br /> Deionized water should be used as the extraction solution in lieu of the citric acid extraction solution. <br /> The deionized water extraction solution would better simulate actual site conditions of rainwater or surface <br /> water infiltration. <br /> After the extraction process, the aqueous extract or filtrate can then be analyzed using the appropriate <br /> methodologies to identify the constituents of concern, namely total petroleum hydrocarbons as diesel and <br /> oil and grease. <br /> A Division of San Joaquin Counry Health Care Services C), <br />