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Handing Lawson Associates —�— <br /> RUCT MAR 1 � <br /> March 16, 1992 <br /> 92006430.02 APR 0 S 1992 <br /> John Bruener Company ENVIRONMENTAL HE T� <br /> 3250 Buskirk Avenue PER M I T/K E% S <br /> Pleasant Hill,California 94523 <br /> Attention: Mr.Peter M.Meier <br /> .Response to Agency Comments <br /> Evaluation of Petroleum Hydrocarbons in Soil <br /> Brueners Stockton Facility <br /> Stockton,California <br /> This letter presents Harding Lawson Associates'response to the San Joaquin County Public Health <br /> Services,Environmental Health Division's(PHS/EHD's)comments on HLA's report titled <br /> Evaluation of Petroleum Hydrocarbons in Soil, Brueners Stockton Facility, Stockton, Californiai dated <br /> September 30, 1991, The report presented the results of an investigation'to evaluate the presence of <br /> petroleum hydrocarbons'in soil beneath a former product dispenser at 7676 Pacific Avenue,Stockton, <br /> California(site). The report also described HLA's soil excavation program in the vicinity of the <br /> former dispenser island. PHS/EHD's comments were presented in their February 20, 1992,letter to <br /> Brueners. <br /> PHS/EHD's comments and HLA's response to those comments are presented below. <br /> PHS/EHD Comment#1 - The sampling on June 6, 1991, by Harding Lawson Associates of the <br /> o3 erexcavation of the soil at the dispenser island area was unwitnessed by PHS/EHD personnel and as <br /> such cannot be accepted as conclusive evidence for consideration for site closure. <br /> i <br /> HLA Response-It is HLA's opinion that the soil sample analytical results are acceptable because soil <br /> sampling and excavation were performed in accordance with HLA work plan dated January 14, 1991. <br /> This work plan was verbally approved by Mr.Michael Inferna of the PHS/EHD on May 30, 1991. In <br /> addition,the work was performed in accordance with standard industry practices and under the <br /> supervision of a California registered geologist. <br /> On June 6, 1991,Mr.Inferna of the PHS/EHD visited the site during soil excavation activities. <br /> However,Mr. Inferna left the site before soil samples were collected from the excavation. Prior to <br /> his departure,he did not inform the onsite HLA field geologist.that his presence was necessary when <br /> soil samples were collected. In addition,HLA has no record that the PHS/EHD informed HLA of <br /> the necessity of a PHS/EHD representative being onsite during soil sample collection. <br /> Engineering and 7655 Redwood Boulevard, P.O. Box 578, Novato,CA 94948 4151892-0821 <br /> Environmental Services A Sabsidia o Nardin Associates <br /> rY f R Offices Na7innNvde <br />