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ENVIRONMENTAL HEALTH DEPARTMENT <br /> oA�U'N SAN JOAQUIN COUNTY <br /> UxitS++pen•isors <br /> Donna K.Reran,R.E.H.S. Carl Borgrnan,R.E.H.S. <br /> fI :< Director304 East Weber Avenue, Third Floor Mike Huggins,R.E.H.S.,R.D.I. <br /> Al Olsen,R.E.H.S. Stockton, California 95202-2708 Douglas W.Nilson,R.E.H.S. <br /> • �.. Program Manager Telephone: (209) 468-3420 Margaret Lagorio,R.E.H.S. <br /> QZ+ko `' Laurie A.Cotuila,R.E.H.S. Robert McClellon,R.E.H.S. <br /> Program Manager Fax: (209) 464-0138 Mark Barcellos,R.E.H.S. <br /> APR 1 4 2004 <br /> DEAN JANSSEN <br /> ACE TOMATO CO INC <br /> 2771 EAST FRENCH CAMP ROAD <br /> MANTECA CA 95336 <br /> RE: Ace Tomato Co., Inc. <br /> SITE CODE 0001557 = <br /> 2771 East French Camp Road <br /> Manteca, California 95336 _ <br /> = r- <br /> San Joaquin County Environmental Health Department (EHD) has reviewed Work Plan f�'r '?n <br /> Limited Immediate Corrective Action at Ace Tomato Facility Located at 2771 E. French Camp <br /> Road in Manteca, California, dated March 17, 2004, prepared and submitted by Wright <br /> Environmental Services, Inc. (Wright) on your behalf. In this report,Wright proposes to remove <br /> contaminated soil found beneath the fill bucket and dispenser for regular unleaded gasoline. <br /> Wright attributes the methyl tertiary-butyl ether (MTBE) and tertiary- butyl alcohol (TBA) <br /> concentrations found in the vadose soil to be the result of minimal leakage from the previously <br /> existing fill bucket and dispenser piping. <br /> EHD does not approve this work plan for the following reasons: <br /> • Wright proposes to hand-excavate between one and ten tons of contaminated soil by <br /> removing approximately three feet of soil beneath the dispenser and fill bucket and <br /> approximately three feet of soil from all four sidewalls surrounding the two defined areas. <br /> EHD does not believe this is a practical approach considering that this area is presently <br /> filled with pea gravel and would be labor intensive to excavate by hand, and there is no <br /> demonstration that the proposed actions would be adequate to address impacted soil. <br /> • This work plan does not address investigating the extent of soil contamination known to <br /> occur at this site. Not all soil samples initially submitted for analysis were analyzed for <br /> fuel oxygenates. Because MTBE and TBA are the contaminants of concern, additional <br /> investigation is needed to determine the vertical and lateral extent of soil contamination. <br /> • Considering the high concentrations of MTBE and TBA found at this site, where soil <br /> tends to be sandy with low sorption capacity, there is a significant possibility that <br /> groundwater may be contaminated with MTBE and TBA. Additional investigation is <br /> needed to assess groundwater for contamination. <br /> Please submit a work plan to EHD by May 28, 2004, that will assess groundwater for <br /> contamination and delineate the vertical and lateral extent of contamination in soil. Soil and <br /> groundwater samples should be analyzed for total petroleum hydrocarbons as gasoline (THP-g) <br /> by United States Environmental Protection Agency (EPA) SW-846 methods 5030/8015B; <br /> benzene, toluene, ethyl benzene, and total xylenes (BTEX) by EPA SW-846 methods <br /> 5030/8021/8260B; and di-isopropyl ether(DIPE), ethyl tertiary-butyl ether(ETBE),MTBE, <br /> I <br />