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Rod Hunter Page 2 <br /> PHS/EHD has determined that based on the additional investigation and the petroleum hydrocarbon soil <br /> contamination which was previously documented, remediation of the documented petroleum <br /> hydrocarbon contamination will be necessary. <br /> Please note that in the future all analytical results should be also in table form to facilitate the <br /> regulatory review of the data. <br /> Remedial Action Plan <br /> The proposed plan addresses only the petroleum hydrocarbon contamination and includes: cleaning of <br /> the concrete tank, disconnection of all piping and removal or closure in place with an inert matter, <br /> excavation of contaminated soil adjacent to the tank and further characterization of the residual <br /> impacted soil, backfilling the excavation, filling the concrete tank with sand and capping the entire site <br /> with an impermeable layer. The excavated soil will be treated on-site. <br /> PHS/EHD concurs with the recommendation to excavate contaminated soils adjacent to the tank to <br /> remove a potential threat of contamination to groundwater. PHS/EHD also concurs with the proposal <br /> to close the tank in place using sand, since at some time in the future it may be possible to excavate <br /> and remove the tank along with any residual soil contamination and due to the close proximity of the <br /> tank to the building. <br /> PHS/EHD additionally recommends that once the tank is cleaned that a soil boring be drilled and <br /> sampled through the bottom of the tank to further assess the vertical extent of residual contamination. <br /> Also, soil samples should be collected from the sidewalls and bottom of the excavation at 20 foot <br /> intervals. Additional remediation and/or investigation of residual soil and potential groundwater <br /> contamination, after the excavation attempt, may be necessary. Please submit a work plan addendum <br /> addressing PHS/EHD's concerns by March 11, 1994. <br /> The RAP did not address the chlorinated hydrocarbon contamination evidenced to date. PHS/EHD has <br /> enclosed a copy of comments dated December 17, 1993 from the Department of Toxic Substances <br /> Control (DTSC). You should contact DTSC for further information and directives regarding the <br /> investigation and remediation of the chlorinated hydrocarbon contamination evidenced at your site. <br /> If you have any questions, please contact Mary Meays, Senior REHS, of my staff at (209) 468-0337. <br /> Ernest M. Fujimoto, M.D., M.P.H. <br /> ealth Officer <br /> Diane Hinson, Supervising REHS <br /> Environmental Health Division <br /> Enclosure <br /> DMH/MM <br /> c: Derrick Adachi, Cal EPA DTSC <br /> c: Nancy Lancaster, Cal EPA DTSC <br /> c: Stephen G. Muir, WZI <br /> c: Fran Forkas, City of Lodi <br />