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PUBLIC HLALTH SERVI&S <br /> SAN JOAQUIN COUNTY <br /> Q: <br /> ENVIRONMENTAL HEALTH DIVISION <br /> Karen Furst, M.D., M.P.H., Health Officer P <br /> 304 East Weber Avenue, Third Floor • Stockton, CA 95200 O n oR' <br /> 209/468-3420 Ir <br /> ED KOBERSTEIN MAR U 2 1998 <br /> MONTGOMERY WARD & COMPANY INC <br /> 1331 SO HARBOR BLVD <br /> FULLERTON CA 92632 <br /> RE: Montgomery Wards Auto Center SITE CODE: 2163 <br /> 5400 Pacific Ave. <br /> Stockton, CA., 95207 <br /> San Joaquin County Public Health Services, Environmental Health Division (PHS-EHD), <br /> has reviewed the "Interim Corrective Action Plan" submitted by Environmental Audit, Inc. <br /> and has the following comments. <br /> In discussions with the State Water Resources Control Board Clean Up Fund Technical <br /> Review Staff, PHS-EHD has been instructed to interpret "interim" corrective action as an <br /> emergency method utilized to correct or abate the effects of an unauthorized release. <br /> For this site, there are no immediate dangers (explosion, drinking water supply impacts, <br /> free product recovery, etc) or other emergency conditions that support the need for <br /> "interim" action. PHS-EHD recommends you modify the document heading so that <br /> there will be no misunderstandings at the SWRCB that may hamper your ability to <br /> acquire the necessary Clean Up Fund (CUF) cost pre-approval. <br /> In order to evaluate the cost-effectiveness of the methods your consultant has <br /> discussed in the Corrective Action Plan (CAP), PHS-EHD will need to be supplied with <br /> the estimated costs and estimated time duration for each method under consideration. <br /> Please provide Mr. Infurna with the complete cost breakdown and time frame estimates <br /> for each alternative evaluated in a revised CAP. <br /> The San Joaquin County Delta College campus irrigation well has been impacted by <br /> petroleum. This fact, in conjunction with the evidence that unauthorized petroleum <br /> releases from the former underground storage tanks formerly operated at this site have <br /> impacted groundwater, necessitates remediation of groundwater contamination. By only <br /> proposing to remediate the soil at Ward's Auto Center, the CAP is incomplete and <br /> cannot be approved by PHS-EHD. You must include groundwater remediation cost- <br /> effective methods in any CAP submitted for PHS-EHD review and subsequent approval. <br /> Historical high groundwater levels now in the San Joaquin Valley have placed sites such <br /> as yours in a position of having the current depth to first groundwater over well screened <br /> intervals. At this site all but one of the seven monitoring are drowned. This condition is <br /> unacceptable for evaluating remedial efforts and prior to enacting any CAP, additional <br /> monitoring wells will have to placed so that the screened interval overlaps the <br /> vadose/saturated zone interface. PHS-EHD recommends that you and your consultant <br /> discuss utilizing the monitoring wells as "air-sparge" wells or as canisters for providing <br /> Oxygen Releasing Compound" (ORC) to the groundwater for enhanced in-situ <br /> A Division of San Joaquin County Health Care Services <br />