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PUBLM., HEALTH SERVICES <br /> SAN JOAQUIN COUNTY <br /> JOGI KHANNA M.D.,M.P.H. <br /> Health Officer <br /> • • Stockton, California 95201 c°��Foa`'�P <br /> P.O. Box 2009 (1601 East Hazelton Avenue) <br /> (209)468-3400 <br /> MELITA ELMORE DIRECTOR (C(31P'L <br /> SAFEWAY ENVIRONMENTAL AFFAIRS <br /> FOURTH AND JACKSON ST MAY 14 1992 <br /> OAKLAND CA 94660 <br /> RE: 1111 Navy Dr. SITE CODE: 1194 <br /> Stockton, CA 95206 <br /> San Joaquin County Public Health Services, Environmental Health Division (PHS/EHD) has completed <br /> our review of the report entitled "Site Assessment Report" dated January 1992 prepared by ERM-West, <br /> Inc. In addition, data received March 30, 1992 from groundwater monitoring wells 4, 5 & 6 was <br /> incorporated in our evaluation of work performed to date. <br /> As it is Safeway's intention to request cessation of groundwater monitoring within the year's end, it will <br /> be necessary for our staff, as well as the Regional Water Quality Control Board's staff to thoroughly <br /> evaluate the leaking underground storage tank investigation. As was discussed with Bill Spong of <br /> ERM-West, the following are recommendations which will help expedite the preparation of your "Final <br /> Remedial Plan". <br /> 1. The site lacks a well up-gradient of the UST system. For reasons described in the above <br /> referenced report, 3 existing monitoring wells were abandoned under PHS/EHD permit. Groundwater <br /> flow directions may be experiencing influences within the area due to increased pumping to compensate <br /> for drought conditions. Additionally, the underground storage tank pipelines from the former diesel <br /> tanks were not removed during the 1987 tank removal event. Removal may have been too difficult with <br /> respect to the close proximity of the fire hydrant line and storm drain. Placing the <br /> up-gradient well near the former fuel lines will provide investigative soil data not previously known. <br /> 2. Diesel contaminated soil remains at depths of 25-30 feet (pg. 2-2, table 2-1) as well as in <br /> those borings sampled in 1989 (B-11, B-14, B-15). Although drinking water maximum contaminate <br /> levels (MCLS) have not been established for TPH-Diesel, the presence of this contaminate within the <br /> saturated zone poses a threat to water quality. Cessation of groundwater monitoring is unlikely as long <br /> as elevated levels of petroleum hydrocarbons remain within the groundwater's range of fluctuation. <br /> 3. Cross-sectional diagrams based upon boreholes, monitoring wells , and hydropunched holes <br /> were not included within the last"Soil Assessment Report", nor were figures delineating the horizontal <br /> and vertical extent of the groundwater contamination plume and the related zones of soil contamination. <br /> In addition, the defined extent of the soil and groundwater contamination ("zero-line") both laterally and <br /> vertically was not provided. These data are essential to the "Problem Assessment Report" and until the <br /> minimum reporting suggestions are satisfactorily completed, steps toward remediation will be premature. <br /> Relative to our letter of October 16, 1990 concerning quarterly sampling, the recent submittal of raw <br /> sampling data is insufficient in detail. Subsequent quarterly reports are to consist of the following <br /> minimum data: <br /> A Division of Son Joaquin Counry Health Care Services �� <br />