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PUBLIC NEALTH SERVICES Q�,M <br /> SAN JOAQUIN COUNTY <br /> ENVIRONMENTAL HEALTH DIVISION <br /> Ernest M. Fujimoto, M. D., M.P.H., Acting Health Officer <br /> 304 E. Weber Ave., Third Floor • P. O. Box 388 • Stockton, CA3 � <br /> 2091468-3420 <br /> BRETT LARSON MAILED DED 2 91995 <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 "Quarterly Groundwater Monitoring Report' dated December 19, 1995 and the <br /> "Remediation Workplan for Stockpiled Soil" dated December 22, 1995, both prepared by ICF Kaiser. <br /> PHSIEHD has the following comments for your consideration. <br /> The quarterly report indicated that groundwater contamination continues to be evidenced and pursuant <br /> to the State of California Underground Storage Tank Regulations, a corrective action plan must be <br /> submitted. <br /> Regarding the work plan for disposal of contaminated soil stockpiled at 1320 West Weber, PHSIEHD <br /> disagrees with the numeric soil cleanup goals which were proposed and which referenced the Leaking <br /> Underground Storage Fuel Tank Field Manual. Based on the depth to groundwater at the 1320 West <br /> Weber site, the leaching potential analysis, as put forth by the Leaking Underground Fuel Tank Field <br /> Manual, indicates that the no-action level for TPH-d is less than that proposed. The leaching potential <br /> analysis which is based on SESOIL modelling indicated that the maximum allowable TPH-d level would <br /> be 100 ppm. If soils exceeding these levels are proposed to remain in place, additional environmental <br /> fate analysis will be necessary. <br /> PHSIEHD concurs that off site disposal to a treatment facility, of small volumes of contaminated soil, is <br /> an effective remedial option. PHSIEHD also recommends that you obtain State Water Resources <br /> Control Board Cleanup Fund pre-approval. <br /> Please contact Mary Meays at (209) 468-0337 if you have any questions. <br /> Donna Heran, REHS, Director <br /> Environmental Health Division <br /> Mary Meays, Senior REHS Diane N1'. Hinson, REHS <br /> Site Mitigation Unit Supervisor <br /> MM1425UNION <br /> cc: Elizabeth Thayer, CVRWQCB cc: Jeff Lawson, Esq. <br /> cc: Lee Hansen, Arctic Ice cc: Dennis Green, Esq. <br /> cc: John Farr, ICF Kaiser <br /> A Division of San Joaquin County Health Care Services <br />