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SERVICESPUBLIC HEALTH <br /> SAN JOAQUIN COUNTY <br /> ENVIRONMENTAL HEALTH DIVISION . <br /> Ernest M. Fujimoto, M.D., M.P.H., Acting Health Officer <br /> 445 N. San Joaquin Street • P.O. Box 388 • Stockton, CA 95201-0388 <br /> (209) 468-3420 <br /> C (OPY <br /> BRETI' LARSON <br /> UNION ICE LIMITED APR 0 4 1994 <br /> 6100 E SHEILA STREET <br /> LOS ANGELES CA 90040 <br /> Site Code: 241434 <br /> Re: Union ice <br /> 425 North Union <br /> Stockton CA 95205 <br /> San Joaquin County Public Health Services, Environmental Health Division (PHS/EHD) has completed <br /> review of the "Work Plan for Verification Sampling for Site Closure" dated March 9, 1994 and prepared by <br /> ICF Kaiser. The PHS/EHD Technical Review Committee has discussed the site and has the following <br /> comments for your consideration. <br /> The work plan proposed to investigate residual soil contamination in two areas of the April 1993 <br /> excavation, the north-west and north-east. Unfortunately, extensive discrepancies were revealed during <br /> review of the WHF map of the excavation and PHS/EHD staff observations during sample collection. <br /> PHS/EHD has identified at least three areas of obvious residual contamination. <br /> The locations and number of samples collected from the excavation and identified by WHF do not <br /> correlate with PHS/EHD staff field notes. The chain of custody for samples collected on April 27 and 28 <br /> 1993 do correlate with PHS/EHD staff field notes with two exceptions. WHF apparently included in their <br /> map a bottom sample collected without PHS/EHD inspection on April 22, 1993. The lab results were not <br /> included in the table and indicated 1,100 ppm kerosene and no BTEX at a 50 ppb detection limit. This <br /> sample was identified as: contamination at bottom of excavation. The addition of this bottom sample <br /> would explain how 13 samples were reported when PHS/EHD was aware of only 12 samples being <br /> collected. <br /> PHS/EHD provided your consultant on February 10, 1994 with copies of PHS/EHD staff field notes from <br /> the excavation. <br /> The number of soil borings proposed will be inadequate to investigate the areas in question. PHS/EHD <br /> recommends that at minimum two additional slant soil borings be drilled in the northern side wall and in <br /> the south-west sidewall. <br /> The work plan indicated that drilling would continue to a 40 foot vertical depth, unless contamination was <br /> observed. PHS/EHD further recommends that at minimum the proposed soil boring in the north-west <br /> corner be drilled to groundwater and, if conditions warrant, the boring should be converted into a <br /> monitoring well. <br /> The work plan did not specify the number of samples which would be collected for analysis of the residual <br /> contamination. Sufficient soil samples should be collected to estimate the volume of residual soil <br /> contamination and thus estimate the vertical and horizontal extent of the soil contamination, in order for <br /> PHS/EHD to determine if additional remediation will be necessary. <br /> A Division of San Joaquin County Health Care Services <br />