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y ! <br /> +1 +r <br /> PUBLIC HEALTH SERVICES ¢� <br /> SAN JOAQUIN COUNTY <br /> • ENVIRONMENTAL HEALTH DIVISION W <br /> Karen Furst, M D , M PH , Health Officer a <br /> 304 East Weber Avenue,Third Floor - Stockton, CA 95202 <br /> 2091468-3420 <br /> PAUL SUPPLE DEC 0 7 2001 <br /> ARCO PRODUCTS COMPANY <br /> P O BOX 6549 <br /> MORAGA CA 95470 <br /> RE ARCO Station #4932 SITE CODE 1136 <br /> 16 E Harding Way , <br /> Stockton CA 95204 <br /> I <br /> San Joaquin County Public Health Services, Environmental Health Division (PHSIEHD)has <br /> reviewed the"Interim Remediation/Multi-Phase Extraction Feasibility Test Report"dated May 10, <br /> 2001 and the"Additional Site Assessment Report"dated November 9, 2001 that were prepared <br /> by SECOR international Incorporated (SECOR)on your behalf and has the following comments <br /> The Feasibility Test Report documents a multi-phase extraction (MPE)pilot test that took place <br /> the week of February 12-16, 2001 Please note that this report was submitted to PHSIEHD four <br /> weeks late The objective of the MPE test, as stated in the work plan dated December 14, 2000, <br /> was to reduce the potential for further migration of dissolved hydrocarbons in groundwater, and to <br /> determine the long-term feasibility of using MPE as a remedial method for the site In addition, <br /> the work plan proposed that laboratory analytical results of groundwater samples collected during <br /> the next quarterly sampling event following the test would be compared to the results of sampling <br /> events completed prior to the test to evaluate the effectiveness of rising MPE to remediate the <br /> petroleum hydrocarbon contaminated groundwater at the site The test was performed with a <br /> dual phase(soil vapor and groundwater)extraction system The test was performed on <br /> groundwater monitoring well MW-4, soil vapor extraction well SVE-1, and a combination of both <br /> wells <br /> During the week of the MPE test, PHSIEHD staff made several visits to the site to observe the <br /> progress of the test and to speak with the SECOR field staff monitoring the test The technician <br /> on site informed PHSIEHD that a pumping test would be performed on MW-2 and MW-4 on <br /> Friday February 16, 2001 When PHSIEHD arrived at the site on Friday morning they were <br /> r informed that the pumping test on MW-2 had been performed the afternoon before The pumping <br /> test on MW-4 was performed on Friday as scheduled However, the report fails to discuss either <br /> of these tests The SECOR technician reported to PHSIEHD that neither well could sustain a <br /> pumping rate of even 0 5 gallons per minute The California Code of Regulations requires <br /> responsible parties to compare at least two cleanup alternatives for their feasibility in mitigating <br /> the contamination and for their cost effectiveness Since two different tests were performed at <br /> this site,two different tests should have been discussed in the report <br /> The report concludes that MPE technology is a feasible remedial alternative for mitigating <br /> hydrocarbon-impacted soil at the site, but makes no comment about mitigation of the <br /> . contamination in the groundwater The report also made no comments on the concentrations of <br /> contamination in the groundwater in samples collected prior to the MPE test as compared to <br /> those collected after the MPE test <br /> rl <br /> DEC 1. 0 2001 �9 <br /> A Division of Sanq ry Jum County oun Hach Care Servj= <br />