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F PUBLIC HEALTH SERVICES <br /> SAN JOAQUIN COUNTY <br /> ENVIRONMENTAL HEALTH DIVISION �§ <br /> Karen Furst, M.D., M.P.H., Health Officer <br /> 304 East Weber Avenue, Third Floor • Stockton, CA 95202r ai; <br /> 209/468-3420 f k-E 0'.. <br /> APR 121999 <br /> BP OIL COMPANY TOSCO MARKETING COMPANY <br /> SCOTT HOOTON DAVID CAMILLE <br /> 295 SW 41ST ST 2000 CROW CANYON PL <br /> BUILDING 13 SUITE N SUITE #400 <br /> RENTON WA 98005-4931 SAN RAMON CA 94583 <br /> RE: TOSCO/BP Service Station #11195 SITE CODE: 1554 <br /> 16500 S. Interstate Five (I-5) <br /> Lathrop,CA., 95330 <br /> San Joaquin County Public Health Services, Environmental Health Division (PHS-EHD) has reviewed <br /> Getder-Ryan Inc. (GRI)March 31, 1999 correspondence received April 4, 1999 and has the following <br /> comments. <br /> GRI reported to PHS-EHD on behalf of TOSCO that a recent groundwater extraction procedure at <br /> the above referenced site has resulted in 107,500 gallons of hydrocarbon contaminated groundwater <br /> being transported offsite for treatment. Also noted in this letter was the advisement that"TOSCO plans <br /> to egnzrrr karer rrvu-d and mumer as kT as srgrrifica zt ra iearmrs in dtss hAri hydro ar,tan ca,�atioru are <br /> l adxia l as a rebut:" <br /> PHS-EHD advises that continued pumping and removal of hydrocarbon contaminated groundwater is <br /> a remedial action. Contaminated underground storage tank(UST) sites are required to have a <br /> Corrective Aaron Plan (CAP) approved by PHS-EHD prior to enacting any remedial activity. <br /> GRI's letter referred to this pumping and removal of the groundwater as an "in a imgxwzk user <br /> nmaiation"' The State Water Resources Control Board(SWRCB) staff has verbally stated that inkymi <br /> remedial actions are emergency activities designed to halt an immediate danger to the public health. In <br /> addition,California Code of Regulations (Title 23,Division 3,Chapter 16, sec 2722(b)) states "Be,6re <br /> taking interan wm=vaazan,dx rt?Twsdk party-,ball no*theVVJXM ag my(PHS-EHD)of the pnpsedaMcn <br /> acrd shall amply uvb any ria mnaz that the nydatmy ageuy sets". PHS-EHD has not received prior <br /> notification from TOSCO or BP concerning this continued groundwater extraction. <br /> A CAP that includes the results of field tests and a cost-effective evaluation of at least two alternatives <br /> for restoring the beneficial uses of the groundwater is to be submitted to PHS-EHD for review prior to <br /> enacting the remedial action at this site. If intervn remedial actions are to be conducted at this site,a <br /> proposal is to be submitted to PHS-EHD for review and approval prior to enacting the activity. <br /> In order to become and/or remain eligible to receive reimbursement for costs incurred for investigative <br /> and remedial activities,the SWRCB requires that all proposals and work plans be approved by,and be <br /> in compliance with,directives issued by PHS-EHD. <br /> A Division of San Joaquin County Health Care Services <br />