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11I Sy {p <br /> f � � <br /> ENVIRONMENTAL HEALTH DEPARTMENT <br /> SAN JOAQUIN COUNTY <br /> >-x- Unit Supervisors <br /> ? Donna K.Heran,R.E.H.S. Ij �I Carl Bor an,R.E.H.S. <br /> 304 East Weber Avenue, Third Floor �" <br /> Director Mike Huggins,R.E.H.S,R.D.I. <br /> 4 Al Olsen,R.E.H.S. Stockton, California 952026 2708. Douglas W.Wilson,R.E.H.S. <br /> ;; - `P.• <br /> Program Manager Telephone: 209 468-342.0 Margaret Lagorio,R.E.H.S. <br /> p ( ) <br /> o Laurie A.Cotulla,R.E.H.S. 1 i Robert McClellon,R.E.H.S. <br /> Program Manager Fax: (209) 464 1 Ol 38 Mark Barcellos,R.E.H.S. <br /> it <br /> JOHN CERVANTES 11 QCT 3 12002 <br /> PO BOX 6008 I .I <br /> STOCKTON CA 95206-6008 <br /> I <br /> RE: JC Trucking i SITE CODE: 2571 <br /> 1207 Aurora Street <br /> Stockton CA 95206 <br /> ill <br /> San Joaquin County Environmental Health Department�(SJC)EHD)ihas reviewed the <br /> "Work Plan to Conduct Remediation Efforts" dated September 27, 2002, as well as the <br /> first and second quarter 2002 groundwater monitoring reports that were prepared on <br /> your behalf by JJW Geosciences Inc. (JJW) and has the following comments. <br /> The current work plan, as well as the previously submitted "Wiork Plan to Conduct <br /> Remediation Feasibility Pilot Tests" dated May 29, 20021 discuss different alternatives <br /> for mitigation of the petroleum hydrocarbon contamination in groundwater that is present <br /> at your site. The different alternatives have been compared for their ability to most <br /> effectively remediate_the contamination and for their costs. JJW had initially proposed to <br /> conduct pilot tests of several of the remediation options, but modified their proposal after <br /> learning that the State Water Resources Control Board Cleanup Fdnd is not approving <br /> cost pre-approvals for testing of multiple remediation methods. The cleanup Fund will <br /> allow testing of multiple remediation methods only if justified by site conditions. For <br /> example, the deeper groundwater contamination may need to be addressed in a <br /> different manner than the shallow groundwater contamination. <br /> JJW has chosen to focus the remediation proposal at this site on tile contaminated <br /> groundwater, stating that there is a lack of detection of'contar minatibln in the soil. <br /> SJCIEHD does not agree with this statement. There have been many detections of <br /> petroleum hydrocarbon contamination in soil at this site, at concentrations as high as <br /> 16,750 milligrams per kilogram (mg/kg) total petroleum jhydro'carbons (TPH), in the C5- <br /> C11 carbon chain range (sample MW-2-3, 15 feet), and 13,000 mglkg TPH as diesel <br /> (sample B-5-25), in the immediate vicinity of the former�underground storage tanks. Soil <br /> contamination has been detected to a depth of approximately 65 feet below surface <br /> grade (bsg), with the highest concentrations located between; 15 and 50 feet bsg. <br /> Current depth to water at the site is approximately 34 feet bsg, indicating there is nearly <br /> 20 feet of vadose zone contamination in the source areas that must be addressed <br /> unless demonstrated that the impacted soil poses no threat to groundwater and human <br /> health, which has not been done. As the site is unpaved and/has only the concrete 1 <br /> foundations from former structures, SJCIEHD recommends that excavation be <br /> considered to address impacted soil in the vadose zone. ' <br /> • <br /> I' � <br />