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f <br /> PUBSIC HEALTH k ICES <br /> SAN JOAQUIN COUNTY r. <br /> JOGI KHANNA M.D..M.P.H. <br /> Health Officer <br /> P.O. Box 2009 • (1601 East Hazelton Avenue) 0 Stockton, California 95201 g 6.14 p <br /> (209)468-3400 <br /> PETER RUHKALA <br /> NOR CAL BEVERAGE COQ <br /> 2266 STONE BLVD JUL 01 1993 <br /> WEST SACRAMENTO CA 95691 <br /> RE: 1800 E. FREMONT STREET SITE CODE: 1106 <br /> STOCKTON <br /> We are in receipt of the report entitled "Soil Excavation Report" <br /> dated June 3, 1993 and prepared by Resna. <br /> Resna's conclusion that "no further action is recommended" implies <br /> that the site investigation has been completed and a closure is <br /> being requested. <br /> Again, San Joaquin County Public Health Services, Environmental <br /> Health Division (PHS/EHD) must disagree with the conclusions of the <br /> report findings. On numerous occasions within correspondence from <br /> this office, you have been directed to provide groundwater data <br /> which demonstrates a high level of confidence. NOR-CAL's (NCBC) <br /> prior request for site closure, April 14, 1992, produced comments <br /> from Ms. Elizabeth Thayer of the Central Valley Regional water <br /> Quality Control Board (CVRWQCB) echoing the concern that due to the <br /> predominance of sands and silty sands, the detection of volatile <br /> organics in two groundwater samplings, and without the minimum <br /> number of monitoring wells to calculate site specific gradient, <br /> closure was premature. <br /> Gradient, in this area, has been documented to the west-northwest. <br /> Seasonal high depth to water has -been documented at 40 feet [San <br /> Joaquin County Flood Control Maps, 1986] . The site has only one <br /> monitoring well located within 10 feet of the tank area. <br /> Uncertainty remains as to its gradient direction verification due <br /> to the lack of well survey information. This requirement was also <br /> stated in Ms. Thayer's evaluation. <br /> Quarterly monitoring reports have not been submitted to this office <br /> since January 1992 . A full year of valuable water quality data has <br /> not been gathered. This is especially unfortunate since our water <br /> table demonstrated a response to the winter rainfall. In a letter <br /> from PHS/EHD dated August 26, 1992 , you were directed to continue <br /> quarterly monitoring of the existing monitoring well until such <br /> time as closure certification was agreed to by both PHS/EHD and the <br /> CVRWQCB. <br /> The recent source removal of residual soil contamination appears to <br /> A Division of San Joaquin Counry Heal[h care Sernces 40 <br />