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PUBLIC HEALTH SERVICES <br /> SAN JOAQUIN COUNTY r. <br /> -a: /N a <br /> ENVIRONMENTAL HEALTH DIVISION <br /> Karen Furst, M.D., M.P.H., Health Officer <br /> 304 East Weber Avenue, Third Floor • Stockton, CA 95202 <br /> 209/468-3420 <br /> BRETT HUNTER NOV 21 1997 <br /> CHEVRON USA INC <br /> P O BOX 6004 <br /> SAN RAMON CA 94583-0904 <br /> RE: Chevron Service Station #9-6171 SITE CODE: 1784 <br /> 6633 Pacific Ave <br /> Stockton CA <br /> San Joaquin County Public Health Services,Environmental Health Division (PHS/EHD) has briefly <br /> reviewed the "Work Plan for Waste Oil Tank, Hoist,and Product Line Removal" which was dated <br /> November 4, 1997 and prepared by Pacific Environmental. PHS/EHD has the following comments <br /> for your response. <br /> The work plan submitted indicated that samples were going to be collected related to the removal of <br /> an underground storage tank,a service hoist and gasoline product lines. The work plan also <br /> suggested that if petroleum saturated soils were encountered that some limited excavation may be <br /> performed. <br /> Please note that the work plan failed to identify the soil contamination evidenced in the area of the <br /> dispenser, in the sample collected by Pacific Environmental on September 22, 1995. Soil boring, B3 <br /> evidenced 56 ppm TPH-gasoline at 2 feet below ground surface (bgs). This boring could not be <br /> advanced to greater depths due to auger refusal, "by something metallic in nature",presumably <br /> abandoned product piping. <br /> The work plan is not consistent with the closure plan which was submitted to PHS/EHD staff, <br /> Michael Kith,which stated that Touchstone would be collecting soil samples. Please provide <br /> clarification regarding the designation of the company responsible for sampling. <br /> The work plan also indicated that a selected sample would undergo EPA Method 8260 analysis. <br /> Please note that Chevron has used an oxygenate other than methyl tertiary butyl ether (MTBE), <br /> specifically Tertiary Amyl Methyl Ether (TAME). All soil samples collected from beneath the product <br /> lines shall undergo EPA Method 8260 analysis. <br /> Finally, there is concern regarding the definition of saturation of petroleum hydrocarbons and the <br /> ability of soils contaminated with less than saturation concentrations to impact groundwater. Please <br /> provide clarifications regarding the intent of Chevron to remediate petroleum hydrocarbon <br /> contamination,prior to replacing the piping. Considerable expense has already been expended <br /> attempting to investigate the dispenser island without interfering with the operation of the existing <br /> piping. If piping is replaced in areas of contamination, it may interfere with the ability to access <br /> these areas to determine the vertical and horizontal extent of any contamination evidenced. <br /> Should Chevron wish to perform interim remediation,a more detailed plan will be required which <br /> describes the maximum cubic yards which will be excavated and the sampling frequency to <br /> A Division of San Joaquin County Health Care Services <br />