Laserfiche WebLink
PUBLIC HEALTH SERVICES <br /> oA4u!N c <br /> SAN JOAQUIN COUNTY <br /> ENVIRONMENTAL HEALTH DIVISION <br /> Ernest M. Fujimoto, M.D., M.P.H., Acting Health Officer •' <br /> 304 E.Weber Ave., 3rd Floor • P. O. Box 388 • Stockton, CA 95201-0388 P'• <br /> 209/468-3420 <br /> DAN KIRK <br /> SHELL OIL PRODUCTS COMPANY MAILED <br /> P O BOX 4023 <br /> CONCORD CA 94524 <br /> RE.- 620 West Charter Way SITE CODE: 1058124 <br /> Stockton, Ca <br /> San Joaquin County Public Health Services, Environmental Health Division (PHS/EHD) has completed <br /> a comprehensive review of the file for this site, the 'Remedial Summary and Proposal for Final <br /> Corrective Action" dated May 26, 1995, and the latest quarterly monitoring report, both submitted by <br /> FUGRO West, Inc. and has the following comments for your consideration. <br /> The request to modify the remediation system at the site is based on the fact that the current <br /> hydrocarbon contain ment/destruction method is no longer cost effective to operate for the amount of <br /> hydrocarbons being removed from the subsurface. However, the modification requested is not to <br /> change to a different type of hydrocarbon contain ment/destruction method or to attempt to enhance the <br /> hydrocarbon removal from the subsurface, but to modify the remediation system to a completely <br /> different technology. Please be advised that any new technology being proposed for implementation <br /> must be shown, with physical data from feasibility studies, to be the most efficient and cost effective <br /> (best available technology) for the site. <br /> In order to minimize the length of time remaining to site certification, some design evaluations/changes <br /> and/or feasibility analysis must be considered and implemented now. The following discussion is <br /> provided as guidance for the additional efforts that are needed to either improve the efficiency of <br /> hydrocarbon removal from the subsurface or if this proves (based on site studies) technically infeasible <br /> or economically unrealistic, the information/data needed to justify leaving contamination in place. <br /> Current state policy dictates that all pollution in water considered beneficial to the state for use as <br /> drinking, industrial or agricultural must be cleaned up to background levels (levels that existed prior to <br /> the discharge). As petroleum hydrocarbons are not naturally occurring in this area, this usually means <br /> nondetectable levels. However, in some cases, existing technology is the limiting factor in reaching <br /> this goal. There also exists in current state policy the provision that when the initial cleanup goal of <br /> background is not achievable using best available technology, or is economically unrealistic, the <br /> discharger may propose to mitigate the pollution to levels that protect the present and future beneficial <br /> uses of the water, which for this area not only include primary and secondary drinking water standards <br /> but also agricultural standards as well. <br /> Therefore, based on the above, before proposing less stringent cleanup goals for this site it must be <br /> shown with physical data from the site that best available technology has been evaluated and <br /> implemented and is not a cost effective approach for the benefit observed. <br /> A Division of San Joaquin County Health Care Services <br />