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e <br /> f <br /> HEALTH SERVICESPUBLIC. ..` , <br /> 'SAN JOAQUIN COUNTY Q � <br /> H: <br /> JOGI KHANNA MD.,M.P.H. <br /> Healch Officer P <br /> P.O. Box 2009 • (1601 East Hazelton Avenue) • Stockton,California 95201 <br /> (209)468-3400 <br /> BOB VASQUEZ <br /> SOUTHLAND CORPORATION <br /> 5820 STONERIDGE MALL ROAD SUITE 310 FEB 1 7 1993 <br /> TON CA 94588. � <br /> PLEASAN � <br />' RE: 7-Eleven Store #2243-20304 �' SITE CODE: 1409 <br /> 455 West Grant Line Road <br /> Tracy CA 95376 <br /> San Joaquin County Public Health Services, Environmental Health Division (PHS/EHD) <br /> has completed review of the "Remedial Action Plan Addendum" dated January 14, 1993 <br /> and prepared by Groundwater Technology. PHS/EHD has the following comments for <br /> your consideration. <br /> PHS/EHD agrees that soil and groundwater remediation of documented petroleum <br /> hydrocarbon contamination is necessary. <br /> F <br /> The Remedial Action Plan Addendum (RAP) proposed remediation in two phases: <br /> Phase I groundwater extraction with groundwater treatment followed by discharge and <br /> Phase II soil remediation, either vapor extraction or soil flushing. <br /> Groundwater extraction is an effective method of groundwater contamination plume <br /> control. The treatment method proposed, carbon absorption, does not require a permit ; <br /> from Cal EPA Department of Toxic Substance Control. The treated groundwater will be <br /> either reinjected under a Waste:Discharge Permit (WDP) or disposed into the storm <br /> drain under National Pollution Discharge Elimination System (NPDES) permit issued by <br /> the Central Valley Regional Water Quality Control Board (CVRWQCB). <br /> The RAP did not adequately address how soil remediation would proceed. Groundwater <br /> extraction without concurrent soil remediation is ineffective because contaminated soil <br /> continues to remain in contact with the groundwater and soil contaminates continue to <br /> leach into the groundwater. <br /> Chemical analysis of soil has indicated extensive soil contamination. Since groundwater is <br /> located at approximately 5 feet below ground surface, results represent capillary fringe <br /> soil. Soil samples were not collected at the time of tank removal to assess the maximum <br /> primary source contamination. The sample results from P-1 (PA) directly downgradient <br /> of the former tank pit detected contamination of 1,300 ppm TPH-gasoline. <br /> Unfortunately, benzene, toluene, ethylbenzene and xylene were not analyzed. <br /> A <br /> A Division of San Joaquin County Hcaldr C1re Services <br /> f � <br />