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PUBLIC H15ALTH SERVICES 'OpO CO <br /> SAN JOAQUIN COUNTY 2 ~3 <br /> ENVIRONMENTAL HEALTH DIVISION <br /> Karen Furst, M.D., M.P.H., Health Officer <br /> 304 East Weber Avenue, Third Floor • Stockton, CA 95202 <br /> 209/468-3420 FELE CO p <br /> THOMAS o'NEILL & ANDREW HYDUKE MAR 91999 <br /> PO BOX 923 <br /> STOCKTON CA 95201 <br /> RE: Valley Motors SITE CODE: 1166 <br /> 800 E. Main St. <br /> Stockton, CA., 95202 <br /> San Joaquin County Public Health Services, Environmental Health Division (PHS-EHD) <br /> has reviewed the "Work Plan for Interim Remediation of Contaminated Soil" submitted <br /> by Upgradient Environmental Consultants (UEC) on February 22, 1999 and has the <br /> following comments. <br /> UEC's proposal is to over-excavate and dispose of 825 to 1825 cubic yards of <br /> petroleum contaminated soil as an "interim corrective action". Although the California <br /> Underground Storage Tank (UST) Regulations state that interim corrective actions can <br /> occur with any phase of corrective action, the State Water Resources Control Board <br /> (SWRCB) Clean Up Fund (CUF) has informed PHS-EHD that they do not consider <br /> excavation of more than 200 cubic yards of contaminated soil as interim corrective <br /> action. The Health and Safety Code [Section 25299.77c (6)] requires PHS-EHD to work <br /> with the responsible party (RP) to seek pre-approval of corrective action costs from the <br /> SWRCB-CUF. Therefore, PHS-EHD will not approve this work as interim remediation <br /> unless you receive pre-approval for this plan from the SWRCB-CUF. <br /> UST sites should have the lateral and vertical limits of the soil and groundwater <br /> contamination defined before preparation of a corrective action plan. Should you wish <br /> to evaluate over-excavation as the method for restoring and/or protecting the beneficial <br /> uses of the groundwater, a feasibility study is required. The study should include field <br /> tests and evaluate the cost-effectiveness of at least two methods of remediation before <br /> proposing a corrective action. <br /> Another option would be to acknowledge in writing that the work is not being directed by <br /> PHS-EHD and that as the responsible party you want to proceed even if the costs are <br /> not reimbursed by the SWRCB-CUF. <br /> A work plan to define the groundwater contamination is to be submitted to PHS- <br /> EHD by April 14,1999. If excavation of the soil without reimbursement of costs is <br /> the option you decide to utilize, please submit the written letter of intention by <br /> April 14, 1999. <br /> A Division of San Joaquin County Health Care Services <br />