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ENVIRONMENTAL HEALTH DEPARTMENT oPou�H c 2s. SAN JOAQUIN COUNTY Donna K.Heran,R.E.H.S. Unit Supervisors Director 304 East Weber Avenue, Third FIoor Carl Borgman,R.E.H.S, ' Al OIsen,R.E.H.S, Stockton, California 95202-2708 Mike Huggins,R.E.H.S.,R.D.I. Program ManagerDouglas W.Wilson,R.E.H.S. L�FORa Laurie A.Cotulla,R.E.H.S. 'Telephone: (209) 468-3420 Margaret Lagorio,R.E.H.S, Program Manager Fax: (209) 464-0138 Robert McClellon,R.E.H.S. Mark Barccllos,R.E.H.S. TERRY TARDITI JUL 2 7 2005 11396 HWY 99 N LODI CA 95240 FILE COPY RE: T & T Trucking, Inc. Site Code: 1627 11396 Hwy 99 Frontage Rd N. RO#: 538 Lodi, CA. 95240 CU F#: 015089 San Joaquin County Environmental Health Department (EHD) has reviewed Work Plan for Remediation Well Installation and Soil Vapor Extraction and Air Sparge Pilot Tests (Plan) dated July 14, 2005 as submitted by Brown and Caldwell and has the following comments. On July 15, 2004, EHD commented on the June 28, 2004 Cone Penetration Testing (CPT) boring report for work done onsite during June 2003. A Site Conceptual Model (SCM) was included in the 2004 report. EHD concurred with your consultant's recommendation that a soil vapor extraction (SVE) test and additional CPT borings were needed since the site's petroleum plume had not been vertically defined. The Plan proposes use of SVE and Air Sparge (AS) as designed by Accelerated Remediation Technologies Inc. (ART). EHD is unfamiliar with ART technology and the datalcase histories, included on the website provided by your consultant, did not address remedial activities specifically for MtBE contamination in ground water. The Sacramento County No Further Action letter included on the website was for a surface spill from a tanker rollover on the Isleton Levee. No site-specific data was included and EHD was unable to verify that remediation of MtBE in ground water was part of this remedial action. The last case study on the website included `barrier well' usage of ART technology for a PCE plume. No other specific data was included with this case to support MtBE plume mitigation by the use of ART technology. The Plan did not include a proposal for additional CPT borings. Of particular concern to EHD, the State Water Resources Control Board (SWRCB), and the Central Valley Region Water Quality Control Board (CVRWQCB) is the placement of long screen intervals in wells at contaminated underground storage tank (UST) sites. The Plan included the installation of two vapor extraction wells, VEW-1 and VEW-2. VEW-1 is fisted as a 100-foot deep, 6-inch PVC well casing, with the screened interval starting at 20 feet below ground surface (bgs) and continuing to 100 feet bgs (total screen length, 80 feet). VEW-2 is detailed as being a 3-inch PVC well casing, 60 feet total depth with the screened interval from 20 feet to 60 feet bgs (total screen length, 40 feet).