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ENVIRONMENTAL HEALTH DEPARTMENT <br /> SAN JOAQUIN COUNTY Unit Supervisors <br /> Carl Borgman,R.E.H.S. <br /> Donna K.Heran,R.E.H.S. 304 East Weber Avenue, Third Floor <br /> a:= A Director Mike Huggins,R.E.H.S.,R.D.I. <br /> Ai Olsen,R.E.H.S. Stockton, California 95202-2708 <br /> Douglas W.Wilson,R.E.H.S. <br /> �.. P Program Manager Telephone: (209) 468-3420 Margaret Lagorio,R.E.H.S. <br /> a ' Laurie A.Cotuila,R.E.H.S. Robert McClellon,R.E.H.S. <br /> FO <br /> �l R` <br /> Program Manager Fax: (209} 464-01 Mark Barceilos,R.E.H.S. <br /> ROBERT STRONG OCT 0 5 2005 <br /> RUTH STRONG PROPERTY <br /> 1871 MIDDLEFIELD AVE <br /> STOCKTON CA 95204 <br /> Re: Ruth Strong Property <br /> 5157 W. Business Loop 205 <br /> Tracy, CA <br /> San Joaquin County Environmental Health Department (EHD) has reviewed the <br /> "Soil and Ground Water Remediation Work Plan" dated September 8, 2005, <br /> prepared by Advanced GeoEnvironmental, Inc. (AGE)for the above referenced <br /> site. EHD does not approve the work proposed as adequate and necessary. <br /> EHD agreed with AGE's recommendation for limited over-excavation of the <br /> contaminated soil to prevent continued leaching of the contamination from the <br /> soil to the groundwater and protect the nearby domestic water wells from being <br /> impacted in a fetter dated August 3, 2005. The work plan proposes excavation of <br /> approximately 2500 cubic yards of soil. Except for approximately 550 cubic <br /> yards of overburden soil that may not be impacted, all of the soil excavated will <br /> be disposed off site. EHD does not agree that this amount of excavation is <br /> limited or necessary. <br /> In addition, the State Water Resources Control Board Cleanup Fund (Cleanup <br /> Fund) is unlikely to reimburse the costs for this amount of excavation and <br /> disposal of contaminated soil. At a site on Linne Road in Tracy, it was proposed <br /> to excavate 1500 cubic yards of soil, based on an aerial extent of 3600 square <br /> feet and a depth of 11 feet. The highest concentrations of contamination in the <br /> soil were 13,600 milligrams per kilogram (mg/kg) of Total Petroleum <br /> Hydrocarbons as gasoline (TPHg) and 171 mg/kg Benzene and the highest <br /> concentrations in groundwater were 7250 micrograms per liter (ug/L) TPHg and <br /> 946 ug/L Benzene. These concentrations of contamination are higher than at <br /> your site. The Cleanup Fund would not preapprove the proposed amount of soil <br /> excavation and disposal so the scope of work was greatly reduced to 400 cubic <br /> yards of contaminated soil to be removed and disposed off site for that case. <br /> The highest concentrations of soil contamination at your site were found below <br /> underground storage tanks 4 and 5 at a depth of 11 feet. From soil sample <br /> analytical results and boring log notes it appears soil contamination begins <br />