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PUBLIC HEALTH SERVICES <br /> SAN JOAQUIN COUNTY <br /> r.� <br /> ENVIRONMENTAL HEALTH DIVISION <br /> Ernest M. Fujimoto, M.D., M.P.H., Acting Health <br /> 304 E.Weber Ave., 3rd Floor • P. O. Box 388 • Stockton, CA 2 1- 8,1 j V �q•. �P <br /> 209/468-3420 <br /> MICHAEL D & SHARON OLIVAREZMA{LED OLT 0 2199'- <br /> 436 W. SCOTTS AVENUE <br /> STOCKTON CA 95203 <br /> RE: WORKPLAN REVIEW FOR 300 SOUTH CALIFORNIA STREET, STOCKTON CA. <br /> SITE CODE #1038 <br /> A workplan regarding further assessment and remediation for the above referenced site submitted <br /> by Clearwater Group Inc. (CGI) has recently been reviewed by San Joaquin County Public Health <br /> Services Environmental Health Division (PHS/EHD). PHS/EHD provides the following <br /> comments noted in the workplan review: <br /> PHS/EHD concurs with CGI proposals to characterize existing soil stockpiles which were <br /> generated as a result of the original tank removal and excavation. PHS/EHD requires the <br /> implementation of the following analytical detection limits and sampling scenario. Stockpiled <br /> soil shall be analyzed at detection limits not to exceed 1 ppm for TPH as gas and diesel, 0.005 <br /> ppm for BTEX components at a sampling rate not to exceed 2 samples per 50 cubic yards <br /> (laboratory compositing) followed by treatment and disposal as needed. <br /> PHS/EHD does not concur with CGI recommendations to evaluate the cost of shoring and <br /> additional excavation of soils within the existing limits of the excavation at this site. The <br /> beneficial rationale for excavation is not apparent to PHS/EHD given the current conditions of <br /> contamination known to exist at this site. The greatest contaminant mass is confirmed by <br /> laboratory analysis to exist at a depths greater than 30 feet below grade which is beyond the <br /> limits of traditional excavation equipment. In the event CGI has additional information regarding <br /> this proposal and its effectiveness, please submit the information as soon as possible to eliminate <br /> further delays in workplan approvals. PHS/EHD recommends backfilling this excavation <br /> allowing for enhanced access to this critical assessment area. <br /> Corrective Action Regulation(Title 23, Division 3, Chapter 16,Article 11, Section 2723) requires <br /> complete assessment for contaminated sites fully defining the lateral and vertical extent of <br /> contaminant distribution. In an effort to maintain cost effective strategies to fully delineate the <br /> extent of contamination at this site PHS/EHD does not concur with CGI proposals to place 5 <br /> A Division of San Joaquin County Health Care Services <br />