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San Joaquin County DIRECTOR <br /> o u AN Donna Heran,REHS <br /> O,.P."' C Environmental Health Department ASSISTANT DIRECTOR <br /> `% 600 East Main Street Laurie Cotulla,REHS <br /> m ' Ij 4.. �' Stockton, California 95202-3029 PROGRAM COORDINATORS <br /> • -� - :'• Carl Borgman,REHS <br /> tNWW.S OV.or /ehd Mike Huggins,REHS,RDI <br /> Website:c9�iFo'RN\P 19 J Margaret Lagorio, REHS <br /> Phone: (209) 468-3420 Robert McClellon, REHS <br /> Fax: (209) 464-0138 Jeff Carruesco,REHS, RDI <br /> APR 0 9 2001 Kasey Foley,REHS <br /> Gene Gabbard Inc. Jim & Sheyla Creel <br /> c/o John Gabbard 640 North EI Dorado Street <br /> 10335 Creek Trail Circle Stockton, CA 95202 <br /> Stockton, CA 95209 <br /> Subject: Gabbard Property SITE CODE: 1090 <br /> 640 North EI Dorado Street <br /> Stockton, CA 95202 <br /> San Joaquin County Environmental Health Department (EHD) has reviewed Work Plan for <br /> Additional Site Investigation dated March 31, 2008, submitted on your behalf by Ground <br /> Zero Analysis, Inc. (Ground Zero) and has the following comments. <br /> In response to EHD directives, the Work Plan proposes installation of one angled <br /> Geoprobe soil boring to investigate the vertical extent of the petroleum hydrocarbon <br /> impact to groundwater near the former underground storage tank (UST) area, and <br /> installation of five soil vapor probes to evaluate the potential for vapor intrusion to the <br /> indoor air from residual petroleum hydrocarbons in soil and groundwater beneath the site. <br /> Ground Zero will also monitor for the presence of free product motor oil in monitoring well <br /> MW-3, review the likelihood that the construction of MW-3 may have contributed to the <br /> occurrence of free product motor oil appearing in the well, and resume quarterly <br /> groundwater monitoring and sampling. <br /> Except for the proposed silica gel cleanup for the total recoverable petroleum <br /> hydrocarbons analysis and the proposed analytical methods for the water sample, the <br /> EHD approves the Work Plan proposals but notes that if the Geoprobe soil boring fails to <br /> reach target depth or to produce a groundwater sample for analysis, a different method <br /> must be utilized to achieve the objectives of this investigation. The Central Valley <br /> Regional Water Quality Control Boards Appendix A — Reports, Tri-Regional Board Staff <br /> Recommendations for Preliminary Investigations and Evaluation of Underground Tank <br /> Sites dated April 16, 2004, specifies that use of "Silica Gel Cleanup is not acceptable..." <br /> and that if natural background compounds are suspected of contributing to high total <br /> petroleum hydrocarbon (TPH) concentrations, then comparison with samples from <br /> background locations may be used to justify adjusting TPH concentrations. Also, EPA <br /> Method 418.1 is no longer used; it was replaced with EPA Method 1664A. Per EHD <br /> correspondence dated December 28, 2007, water samples should be analyzed for <br /> benzene, toluene, ethylbenzene, xylenes, fuel oxygenates, TPH as gasoline, TPH as <br /> diesel, TPH as kerosene and TPH as oil and grease. Also per the Tri-Regional <br /> Guidelines, add semi-volatiles by EPA Method 8270C to the analytical suite for the grab <br /> groundwater sample. <br />