SITE INFORMATION AND CORRESPONDENCE

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San Joaquin County DIRECTOR Environmental Health Department Donna Heran, RENS �o.;• ' c° ASSISTANT DIRECTOR 600 East Main Street Laurie Cotulla. REHS VY Stockton, California 95202-3029 PROGRAM COORDINATORS i •/ _ - Carl Borgman, REHS Mike Huggins, REHS, RDI Website: www.sjgov.org/ehd Margaret Lagorio, REHS Phone: (209) 468-3420 Robert McClellon, REHS Fax: (209) 464-0138 ,teff Carruesco, REHS,RDI Kasey Foley, REHS June 30, 2008 Linda Migliori 2881 N. Arata Rd Stockton, CA 95215 Subject: Three Palms Grocery SITE CODE: 1830 6732 Hwy 88 Stockton, CA The San Joaquin County Environmental Health Department (EHD) has reviewed "Corrective Action Plan for Three Palms Grocery" (CAP) dated June 18, 2008, prepared by ATC Associates Inc. for the above subject site and provides the following comments. In the Background Information it states that underground storage tanks (UST's) #4 and #1 were closed in place, #3 was removed and that two other UST's remain in place. Please note that UST's #2 and #5 were removed in February 2005 and there are no operating tanks at this site so the Background Information should be updated accordingly. The CAP discussed soil remedial alternatives of natural attenuation, vapor extraction and excavation and recommended vapor extraction. The CAP did not provide costs for the remedial alternatives and evaluate their cost-effectiveness. Please note that contaminated sites are to be cleaned up in a reasonable time and the Central Valley Regional Water Quality Control Board (CVRWQCB) has indicated that a 10 year time period should be considered. Natural attenuation as a remedial alternative will not meet this time frame. The CAP should provide details and costs for comparison of excavation and vapor extraction and recommend the most cost-effective remedial alternative for the soil. The CAP discussed groundwater remedial alternatives of pump and treat and natural attenuation and recommended natural attenuation. The CAP did not provide costs for the groundwater remedial alternatives either. The pump and treat alternative states that treated water would be discharged into the City of Stockton sanitary sewer if allowed by the City of Stockton. Please note that there are no City of Stockton services at this site. The water would have to be stored on site and transported to an appropriate disposal facility. The typical pump and treat alternative will likely not be cost-effective. Perhaps, remediation of the contamination in the soil will prevent further leaching of the contaminants into the groundwater and natural attenuation will clean up the groundwater in a reasonable time. Other remedial alternatives such as batch extraction and disposal, air sparging, biosparging or in-situ oxidation should be evaluated. Since it is first encountered groundwater that is contaminated and during the summer and fall months the shallow screened wells are often dry, vapor extraction or dual phase extraction may be viable remedial alternatives as well.