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PUBLrk, HEALTH SERCCES <br /> .G <br /> SAN JOAQUIN COUNTY 'yam <br /> JOG[KHANNA M.D.,M.P.H. ' <br /> Health Officer � �p <br /> 4��F�.aei <br /> P.O. Box 2009 • (1601 East Hazelton Avenue) Stockton, California 95201 <br /> (209) 4683400 <br /> MAY 13 9991 <br /> D <br /> JERRY MOORE <br /> MOORE PETROLEUM <br /> P O BOX 67 <br /> BANTA CA 95304 <br /> RE: Franks Exxon #4 IN REPLY REFER TO SITE CODE: 1600 <br /> 14800 S. Hwy 99, Manteca <br /> Public Health Services, Environmental Health Division (PHS/EHD) has reviewed your Report of Soil <br /> Stockpile Analytical Testing dated April 2, 1991, submitted by Aegis Environmental. A proposal for soil <br /> sampling and final disposition should have been submitted to this office and Central Valley Regional Water <br /> Quality Control Board (CVRWQCB) prior to the activity for review and comment. The soil samples should <br /> not have been composited. Discreet soil samples should have been analyzed in order to verify that there are <br /> not areas of contaminated soil remaining. Concurrence from CVRWQCB must be obtained in order to move <br /> the soil from a contaminated site to a pristine site. <br /> Upon review of our file and previous reports submitted for this site,it is evident that zero lines from soil and <br /> groundwater contamination have not been verified. We are aware that Aegis Environmental has recently <br /> become the consultant for this site. They performed groundwater sampling and took groundwater level <br /> measurements in January, 1991 and April, 1991. This information should be used to propose placement of <br /> additional monitoring wells and soil borings at the site. A work plan for additional monitoring wells and <br /> soil borings should be submitted by June 25, 1991. <br /> Soil venting components were installed in the tank basin and beneath product lines in November/December <br /> 1989. If the soil venting system is to be completed, the final design should be submitted as part of a Final <br /> Remedial/Corrective Action Pian or as an Interim Remedial/Corrective Action Plan. Also, a permit from San <br /> Joaquin County Air Pollution Control District (APCD) must be obtained. <br /> Groundwater extraction was previously proposed along with an injection well. An injection well or discharge <br /> of the extracted water to land would require approval from CVRWQCB. In addition, air stripping of <br /> extracted water as previously proposed would require a permit from APCD. Groundwater extraction at this <br /> time may not be adequate to treat the entire plume of groundwater contamination since the plume has not <br /> been physically defined. <br /> Before any remedial/corrective activities commence, a draft interim remedial/corrective action or final <br /> remedial/corrective action plan must be submitted to this office and CVRWQCB. Pursuant to Section 280.67, <br /> Subpart F of 40CFR of the Federal Register, PHS/EHD will conduct a public notice to consider comments <br /> on the proposed plan before it is approved. <br /> At the April 1991 water sampling, it was noted that electrical conductivity, pH, and temperature were not <br /> being measured prior to sampling. In the future, these items should be measured to ensure stability of the <br /> water prior to sampling. Also, future sampling for this site should include testing for total lead since regular <br /> gas is stored at the site. In addition, water from the on-site well should be tested for TPH as gasoline and <br /> diesel, BTXE, EDB and total lead. <br /> A Division of San Joaquin County Health Care Services �� <br />