SITE INFORMATION AND CORRESPONDENCE

Home Browse Search

44i tJ 4 ury • Our agency has repeatedly requested a feasibility study evaluating at least thl-ee— possible remedial actions. Apparently rather than do this, a petition to this Board was considered more feasible. • And while we are discussing soil excavation, we note that one of the supporting facts mentioned is that considerable contaminated soil has already been removed. Any debate regarding the exact amount of soil removed aside, the staff report mentions several times that the highest levels of soil contamination were located in the area of the dispenser islands. Since no over-excavation occurred in this area, it seems logical to conclude that the soils with the highest contaminant levels were not excavated. • We dispute the assertion that there is no evidence of MTBE in the groundwater as a result of this release. If the MTBE levels were related to "atmospheric fallout," would they not be detected in all of the wells? The MTBE levels noted appear to be consistent with pre-1992 releases. • Our staff are currently involved in oversight of 157 leaking UST sites in the Stockton area which have groundwater contamination. 13 of these sites are along Pacific Avenue that has a total length of less than 7 miles. If 130,000 ppb of TPHg and 9,700 ppb of benzene are now the target levels for remediation, the cumulative impact on the groundwater resources of our community will be tremendous. Not to mention the economic impact on adjacent property owners who must disclose these types of"known defects"to potential buyers and lenders. • The San Joaquin County Environmental Health Division strongly recommends that the proposed Order be amended to allow our agency and the CVRWQCB to request further definition of the full vertical and lateral extent of contamination at this site and preparation of a feasibility study to evaluate remediation alternatives.