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PUBLIC HEALTH SERVgCES �oPA!!ry <br /> SAN JOAQUIN COUNTY <br /> z <br /> ENVIRONMENTAL HEALTH DMSION "'• ` <br /> Karen Furst, M.D., M.P.H., Health Officer <br /> cs7�';�oR�vF <br /> 304 East Weber Avenue, Third Floor Stockton, CA 95202 <br /> 209/468-3420 FILE COPY <br /> BRETT HUNTER <br /> CHEVRON USA PRODUCTS COMPANY AUG 181995 <br /> PO BOX 6004 <br /> SAN RAMON CA 94583-0904 <br /> RE: Former Chevron #9-4054 SITE CODE: 1780 <br /> 2103 Country Club Blvd. <br /> F/!d/ee Stockton, CA., 95204 <br /> CM U4W <br /> San Joaquin County Public Health Services, Environmental Health Division (PHS- <br /> EHD), has reviewed the July 15, 1998 "Corrective Action Plan" (CAP) submitted on July <br /> 16, 1998 by Terra Vac Consulting and offers the following comments. <br /> PHS-EHD concurs with your consultants conclusion that soil vapor extraction in <br /> combination with groundwater air sparging (SVE/AS) would be the most cost-effective <br /> method of remediation for this site. <br /> Water quality goals/objectives discussed in the CAP were based on a "calculated Site <br /> Specific Target Level for Benzene in groundwater at 0.054 mg1l". Your consultant <br /> applied Groundwater Services Inc., / Risk Based Corrective Action Tier One models to <br /> this site as an accepted procedure for conducting and evaluating the need for <br /> groundwater remediation. The model results showed that Benzene had a calculated <br /> Risk Baseline Screening Level of 0.054 mg/I and concluded, "To achieve reasonable <br /> water quality, the representative Benzene concentration should be reduced to the Site <br /> Specific Target Level of 0.054 mg/l." This approach is not accepted as a basis for <br /> establishing the need for remediation or for establishing the clean up levels. The CAP <br /> must be modified to include the following requirements. <br /> Underground Storage Tank Regulations [CCR, Title 23, Div 3, Chapter 16, Sec <br /> 2725(f)(2)] stipulates that "sites where an unauthorized release affects or threatens <br /> waters with current or potential beneficial uses designated in water quality control plans <br /> (Basin Plan) shall identify and evaluate at least two alternatives for restoring or <br /> protecting these beneficial uses." <br /> The Central Valley Regional Water Quality Control Board (CVRWQCB) in the Basin <br /> Plan has designated the groundwater in this area as "beneficial use" and under <br /> provisions within the Porter-Cologne Water Quality Control Act states, "Water quality <br /> objectives for groundwaters designated for domestic or municipal (beneficial) use shall <br /> A Division of San Joaquin Counry Hcalth Care Services <br />