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N <br /> N ENVIRONMENTAL HEALTH DEPARTMENT <br /> SAN JOAQUIN COUNTY <br /> Q40, <br /> Uuit Supen isors <br /> Donna K. Heran, R.E.H.S. Carl Bor man, R E H S . <br /> Director 304 East Weber Avenue, Third Floor sAI Olsen, R.E.H.S. Stockton, California 95202-2708 Mike Huggins, R.E.H.S , R.D. I . <br /> Douglas W. Wilson, R.E.H.S . <br /> Prograar Manager Telephone: (209) 468-3420 Margaret Lagorio, R.E.H.S. <br /> Laurie A. Cotulla, REMS, Fax : (209) 464-0138 Robert McClellon, R.E.H.S . <br /> Program Manager Mark Barcellos, R.E.H.S, <br /> RODGER LISTON APR 1 3 2004 <br /> DARPETRO INC USA SERVICE STATION <br /> 3450 EL CAMINO <br /> CERES CA 95307 <br /> RE: DARPETRO, INC Site Code: 1060 <br /> 749 E CHARTER WAY <br /> STOCKTON, CA 9520 <br /> San Joaquin County Environmental Health Department (EHD) has reviewed Amended <br /> Site Concept Model (SCM-A), dated 17 November 2003 , prepared on your behalf by <br /> California Geophysical Group, Inc. (CGG). The SCM-A was received by EHD on 21 <br /> November 2003. EHD also has discussed the SCM-A with Mr. James Barton of the <br /> Central Valley Regional Water Quality Control Board (CVRWQCB). <br /> A copy of Quarterly Report October 2003 was received by EHD on 14 November 2003 <br /> and Quarterly Report January 2004 was received on 17 February 2004. The quarterly <br /> reports were also reviewed by EHD ; comments are provided below. During this review, <br /> EHD has updated its site chronology and integrated the pertinent findings and data to <br /> evaluate CGG's interpretation that the methyl tert-butyl ether (MTBE) is originating from <br /> an up-gradient source. <br /> The SCM-A lists the historical stages of the site investigation and references the reports <br /> containing the results and data of the various investigations. Some of the findings of <br /> each stage of investigation or specific data that CGG draws on for their interpretations <br /> are noted in the Geology section . The section titled 'Geology' describes the upper 70 <br /> feet or so of soil types (lithology) underlying the site as consisting of 19 to 22 feet of silty <br /> clay and clayey silt underlain by 3 to 5 feet of silty sand , underlain by 23 to 25 feet of <br /> silty clay, which overlies approximately 20 feet of silty sand , which in turn is underlain by <br /> clay of unknown thickness . The contaminant distribution encountered in the borings <br /> advanced on the site was discussed in very general terms. There were no summary <br /> descriptions or calculations of contaminant masses and distribution in soil included in <br /> this or any other portion of the SCM-A. The SCM-A included three cross sections and a <br /> reference map showing the lines of cross section and monitoring well locations . <br /> It is the opinion of EHD that the amended site conceptual model (SCM), as presented, <br /> still does not adequately demonstrate the professional interpretations and opinions <br /> advanced by CGG in the SCM-A. There was no summary of conclusions and <br /> interpretations presented by CGG, but EHD believes the following to be CGG's main <br /> points and interpretations : <br /> j <br /> i <br />