SITE INFORMATION AND CORRESPONDENCE

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t San Joaquin County DIRECTOR °P'" Environmental Health Department DonnaHeran,REHS O. _ C ASSISTANT DIRECTOR 600 East Main Street Laurie Cotulla,REHS UA ` :{ Stockton, California 95202-3029 PROGRAM COORDINATORS • Mike Huggins,REHS, RDI Website: vvvvw.s ov.or /ehd Margaret Lagorio, REHS Wit `►<<i`oAN 19 9 Robert McClellan, REHS Phone: (209) 468-3420 Jeff Carruesco, REHS,RD) Fax: (209)464-0138 Kasey Foley, RENS February 26, 2009 Walter and Lenna Shockey Tr. c/o Lee Shockey 117 Goodale Ct. Manteca, CA 95337 Subject: Shockey Trucking 850 Milgeo Avenue Ripon, CA 95366 The San Joaquin County Environmental Health Department (EHD) has reviewed Request for Written Response to Reports and Recommendations (the Request), dated 18 February 2009 prepared by Advanced GeoEnvironmental, Inc. (AGE) on your behalf and the documents referred to in the Request. The Request contained AGE comments about EHD staff discussions with you on the lack of effective progress towards active remediation being performed at the site and expressed confusion over the discussions since the reports referenced in the request contained recommendations for action and the EHD had not commented on the reports. The EHD provides the following response: Directives are made to responsible parties not consultants and the responsible parties have to ensure that the consultants keep them in compliance with regulatory agency directives. The EHD considers you to have been under directive to prepare a feasibility study (FS) and corrective action plan (CAP) for interim remediation for nearly 10 years. AGE has provided a site chronology that states "21 April 1999: EHD directed full delineation of the vertical and lateral extent of soil and ground water contamination and perform feasibility studies to evaluate remedial alternatives for cleanup. After the feasibility study is completed, a CAP is required to be submitted by 01 August 1999." The chronology continues with "10 ,lune 1999: AGE recommended in the quarterly report to prepare the CAP as required by the PHS-EHD for ground water remediation at the site." While the EHD is gratified when consultants recommend following EHD directives, the EHD usually does not believe it necessary to approve recommendations to follow the EHD directives. Note that in AGE's chronology, several quarterly reports are cited to have issued the recommendation to "continue quarterly ground water monitoring"; one would not expect the EHD, in response, to reissue a directive letter to continue to conduct quarterly monitoring. The directive of 21 April 1999 was justified by the identification of three wells in a sensitive receptor survey; the three wells had been constructed with 50-foot sanitary seals and gravel pack, one such well within 350 feet of your site. Although work has been done to partially satisfy the 21 August 1999 directive, it has not yet been fully addressed and the directive has not been rescinded - it is still in effect. Comment and Directive Letter 0209