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.� <br /> PUBLICEEALTH SERVICES <br /> �,QurN <br /> SAN JOAQUIN COUNTY ='gam c41 <br /> ENVIRONMENTAL HEALTH DIVISION <br /> Ernest M. Fujimoto, M. D., M.P.H., Acting Health Officer <br /> 304 E. Weber Ave., Third Floor • P. O. Box 388 • Stockton, CA 95201-0388 �4ciFOR�`P <br /> 2091468-3420 �-�--- <br /> C (a <br /> KYLE CHRISTIE .SES <br /> ARCO PRODUCTS COMPANY <br /> PO BOX 612530 <br /> SAN JOSE CA 95161 <br /> RE: ARCO Station #2076 SITE CODE: 1349 <br /> 800 East Kettleman Ave <br /> Lodi CA 95242 <br /> San Joaquin County Public Health Services, Environmental Health Division (PHS/EHD) has <br /> completed review of the "Evaluation of Hydrocarbon Mass and Distribution" dated July 26, <br /> 1996 which was prepared by Erncon. On September 3, 1996, PHS/EHD discussed with <br /> Erncon representatives, Jay Johnson and Mark Capp, several issues regarding the above <br /> mentioned report. PHS/EHD has prepared the following comments for your information that <br /> briefly summarizes the September 3, 1996 discussion. <br /> PHS/EHD questioned the use of the formula, designed to roughly estimate the maximum <br /> depth of migration of bulk hydrocarbons, that is found in James Dragun's The Soil Chemistr <br /> of Hazardous Materials (1988), for evaluating the threat that the soil contamination evidenced <br /> at the site poses to groundwater. The formula is described by Dragun as non-rigorous and is <br /> specifically designed to estimate the volume of soil necessary to immobilize a volume of bulk <br /> hydrocarbons from a catastrophic leak. The formula was solved incorrectly and was used to <br /> estimate a volume of hydrocarbon released, given groundwater has not been currently <br /> contaminated. The formula should not be used to evaluate the threat to groundwater which <br /> contamination at the site may pose, particularly if the leak was over a period of time rather <br /> than catastrophic. PHS/EHD understands problems associated with predicting the <br /> environmental fate of contaminants and hopes that a more acceptable methodology will be <br /> selected. <br /> The estimates of contaminant masses that were presented utilized contours which described <br /> lower concentration limits rather than the maximum or in the case of more than one analytical <br /> result within a contour, the average. An example was the contour around the piping sample, <br /> PL5 within which 28,000 ppm TPH-gas was detected, but 10,000 ppm TPH-gas was used for <br /> the estimation. Contours should be used to estimate boundaries of contaminant concentrations <br /> and should reflect actual analytical data. <br /> A Division of San Joaquin County Health Care Services <br />