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PUBLIC PlEALTH SERVICES a�,N <br /> SAN JOAQUIN COUNTY <br /> t.. <br /> ENVIRONMENTAL HEALTH DIVISION y; <br /> Ernest M. Fujimoto, M. D., M.P.H., Acting Health Officer <br /> 304 E. Weber Ave., Third Floor * P. O. Box 388 • Stockton, CA 952 038 4c, RaNP <br /> 2091468-3420 <br /> BRETT LARSON MLED APR ? 0199E, <br /> UNION ICE LIMITED <br /> 6100 E SHEILA STREET <br /> LOS ANGELES CA 90040 <br /> Re: Union Ice Site Code: 241434 <br /> 425 North Union <br /> Stockton CA 95205 <br /> San Joaquin County Public Health Services, Environmental Health Division (PHSIEHD) has completed <br /> review of the "Soil Vapor Investigation Workplan " and the "Revised Remediation Workplan for <br /> Stockpiled Soils" both dated January 11, 1996 and prepared by ICF Kaiser. PHSIEHD has the <br /> following comments for your consideration. <br /> The proposed work plan to further evaluate the possible additional sources of contamination to <br /> groundwater contamination included drilling using either a direct-push hydraulic or percussion drive- <br /> point sampling system to collect soil vapor samples. The work plan proposed seven sampling <br /> locations and indicated that gas samples would be collected at 15, 30 and 45 feet. Pursuant to a <br /> telephone conversation on February 13, 1996 with Walter Floyd of ICF Kaiser, the samples would <br /> undergo analysis using an on site laboratory and that the costs of analysis were included with the <br /> drilling costs. Soil gas surveys are generally very useful when defining plumes; however its usefulness <br /> to confirm additional source material, not previously detected, is questionable. PHSIEHD suggests that <br /> soil samples be collected as well for confirmation of soil gas analytical results. <br /> When the drilling permit application is submitted, along with the $89 permit fee, please indicate on the <br /> permit application that the borings will be destroyed using neat cement rather that bentonite chips. <br /> As PHSIEHD indicated in correspondence dated December 29, 1995, PHSIEHD concurs that off site <br /> disposal to a treatment facility, of small volumes of contaminated soil, is an effective remedial option. <br /> The revised work plan proposed to dispose of all stockpiled soils exceeding 100 ppm TPH-diesel. <br /> PHSIEHD recommends that the stockpiled soil with residual contamination that is less than 200 ppm <br /> TPH-diesel, be further evaluated to determine the actual threat which may be posed should this soil <br /> remain in place. PHSIEHD concurs with the off site treatment and disposal of approximately 150 cubic <br /> yards of significantly contaminated (up to 11,000 ppm TPH-oil and 5,500 ppm TPH-diesel) soil. <br /> If you have any questions, please contact me at (209) 468-0337. <br /> Donna Heran, RENS, Director <br /> Environmental Health Division <br /> Mary Meays, Senior REHS Margaret Lagodo, REHS <br /> Site Mitigation Unit Lead Senior <br /> MM1425UNION <br /> c: Elizabeth Thayer, CVRWQCB c: Jeff Lawson, Esq. <br /> c: Lee Hansen, Arctic Ice c: Dennis Green, Esq. <br /> c: John Farr, ICF Kaiser <br /> A Division of San Joaquin County Health Care Services <br />