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ENVIRONMENTAL HEALTH bEPARTMENT <br /> �PaU'" SAN JOAQUIN COUNTY <br /> ..�,�:r•.o� Program Coordinators <br /> z.. < <br /> Donna K. Heran, R.E.H.S, 304 East Weber Avenue,Third Floor Carl Borgman, R.E.H.S. <br /> Director Mike Huggins, R.E.H.S., R.D.i. <br /> Laurie A. Cotulla, R.E.H.S. Stockton,California 95202-2708 Margaret Lagorio, R.E.H.S. <br /> • ..: ° <br /> Telephone: (209)468-3420 Robert McClellan, R.E.H.S. <br /> Assistant Director <br /> Fax: (209)464-0138 Jeff Carruesco, KE ES. <br /> Website:www.sjgov.org/ehd/ Kasey Foley, R.E.H.S. <br /> PORT OF STOCKTON NOV 0 2 2006 <br /> JEFF WINGFIELD I RITA KOEHNEN <br /> 2201 W. WASHINGTON ST <br /> STOCKTON CA 95201 <br /> RE: UST Site #3 Site Code: 1282124 <br /> Port Rd 13 at G St RO#: 0673 <br /> Stockton, CA. 95201 CUF#: 013777 <br /> San Joaquin County Environmental Health Department (EHD) has reviewed <br /> Closure Report (CR) and Request for No Further Action Required received <br /> August 18, 2006 and has the following comments. <br /> The EHD has reviewed the soil and ground water data included in the GeoMatrix <br /> report from April 2003 in order to obtain information not included in the CR. <br /> Additionally the EHD completed the Checklist of Required Data for Closure of <br /> Underground (Storage) Tank (UST) Sites—Appendix B, Tri-Regional Guidelines <br /> since this document was also not included in the CR. <br /> Although your consultant provided a good argument for closure consideration, <br /> the EHD cannot concur with your request for closure at this time. The following <br /> concerns must be adequately addressed before the EHD can concur with your <br /> consultant that the site qualifies for no further action. <br /> Of particular concern to the EHD is the lack of vertical ground water plume <br /> definition in the former UST pit. Although some soil boring/ground water grab <br /> data collected can be used to support vertical ground water plume definition <br /> outside the former UST pit area, some is ambiguous. The vertical extent below <br /> the most contaminated monitoring wells in the UST pit area, MW3-3 and MW3-2, <br /> is still not adequately defined. Additional investigation is warranted. The EHD <br /> will require discrete ground water data from this area before a closure evaluation <br /> can be accepted. A work plan to gather this data is due at the EHD within sixty <br /> (60) days. <br /> Whether on not dissolved petroleum contamination is detected at deeper <br /> locations in the former UST pit, the ground water petroleum concentrations in <br /> monitoring wells MW3-1, 3-2, 3-3, and 3-6 exceed levels that the Central Valley <br /> Regional Water Quality Control Board (CVRWQCB) normally has accepted for <br /> closure concurrence. <br />