SITE INFORMATION AND CORRESPONDENCE

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ENVIRONrVIENTAL HEALTH DEPARTMENT SAN JOAQUIN COUNTY Donna K. Heran, R.E.H.S. Unit Supervisors :< Director 304 East Weber Avenue,Third Floor Carl Borgman,R.E.H.S. Laurie A. Cotulla, R.E.H.S. StOCktOn,California 95202-2708 Mike Huggins, R.E.H.S., R.D.I. . Program Manager Douglas W. Wilson, R.E.H.S. Q<<Foaa• Telephone: (209)468-3420 Margaret Lagorio,R.E.H.S. Fax: (209)464-0138 Robert McClellon, R.E.H.S. Website:www.sjgov.org/ehd/ Jeff Carruesco, R.E.H.S. SWARAN CHOUHAN 20% 3035 MAYTEN CT STOCKTON CA 95212 RE: K & S Gas & Grocery Site Code: 2512 701 E Charter Way Stockton, CA San Joaquin County Environmental Health Department (EHD) has reviewed Soil Vapor Extraction Feasibility Work Plan (WP), dated 10 January 2006, prepared and submitted by Advanced GeoEnviron mental, Inc. (AGE) on your behalf to address the directive issued by EHD by letter dated 28 September 2005 to initiate interim contaminant mass removal and gain hydrological control of your plume for shallow groundwater. The dissolved contaminant plume originating from your release has not been fully delineated laterally or vertically, but due to the relatively small size of your site, the high concentrations of contaminants dissolved in groundwater, and the known vertical extent of impacted groundwater on your site, EHD believes that it is highly probable that your plume is unstable and migrating off-site, potentially impacting additional groundwater. The directive letter of 28 September 2005 was issued to mitigate the impact of your plume while the site investigation continues. The WP proposes soil vapor extraction (SVE) as an interim remedial action. EHD was not able to discern how interim soil remediation would mitigate migration of the intensely impacted groundwater. Discussing the proposed method directly with your consultant, AGE believed it important to address the soil source feeding the contaminants to groundwater as the best use of the limited space available on your site for a remediation system. An EHD representative visited your site on 24 January 2006 with a representative of AGE to discuss other remedial alternatives for your site. Dual phase extraction or separate SVE and groundwater extraction systems were discussed. The WP is not approved as submitted as it does not address either EHD's directive or concern. Submit a revised WP by 01 March 2006 that demonstrates how SVE alone will achieve the directive objectives outlined in the EHD letter of 28 September 2005 or a WP that proposes and justifies other remedial approaches that will meet the directive objectives (interim plume control and nnntaminant mass rPciuctinnl