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PUBLIC HEALTH SERVICES <br /> SAN JOAQUIN COUNTY w x <br /> ENVIRONMENTAL HEALTH DIVISION <br /> Karen Fursr, M.D., MTH., Health Officer ` <br /> 304 East Weber Avenue, Third Floor • Stockron, CA 95202 <br /> 2091468-3420 <br /> JAMES MUNCH <br /> STATE WATER RESOURCES CONTROL BOARD JAN 16 IM <br /> UNDERGROUND STORAGE TANK CLEANUP FUND <br /> P O BOX 944212 <br /> SACRAMENTO CA 94244-2120 <br /> RE: UNOCAL REQUEST FOR CLOSURE FOR SITE AT <br /> 1665 PACIFIC AVENUE, STOCKTON <br /> San Joaquin County Public Health Services, Environmental Health Division (PHSIEHD) <br /> staff as discussed with you at a meeting on December 3, 1997, believe further <br /> investigation of the above referenced site is needed. We have concerns with <br /> UNOCAL's failure to determine the lateral and vertical extent of contamination at this <br /> site prior to their submission of a closure request to you, as well as statements made in <br /> that closure request. The following comments highlight some our concerns. <br /> According to PHSIEHD records, on March 29, 1988, two 10,000 gallon unleaded <br /> underground storage tanks (UST's) and one 500 gallon waste oil tank were removed <br /> from the site. About 100 cubic yards of soil was generated during this activity <br /> (inspection report enclosed). Odor was noted in soil samples collected from beneath <br /> the unleaded UST's on the west side of that excavation, at a depth of about 16 feet <br /> below ground surface (bgs). <br /> On March 30, 1988, further excavation of the west side of the former unleaded UST's <br /> excavation was performed. The original unleaded UST's excavation was enlarged to <br /> about 25 feet by 35 feet and benched for an excavator. The original excavation was <br /> about 12 foot deep. Dimensions of the area further excavated was about 25 feet by 10 <br /> feet by 26 foot deep. A soil sample was collected at this depth. About 80 to 100 cubic <br /> yards of soil were generated and stockpiled on site during this work (inspection report <br /> enclosed). <br /> Apparently further excavation and soil sampling of this area of the excavation to a depth <br /> of 30 bgs was conducted without PHSIEHD observation. Soil sample locations shown <br /> on the Applied Geosystems (AGS) map would support that only the west side of the <br /> former unleaded UST's location was further excavated (map enclosed). In a letter dated <br /> August 3, 1988 (copy enclosed), AGS stated that the hydrocarbon contaminated soil <br /> was removed from the site to 221 N. Cardinal Street, Stockton. The approximately 350 <br /> cubic yards of soil was placed on plastic at the Cardinal Street address. <br /> UNOCAL and Pacific Environmental Group (PEG) have stated that 1104 cubic yards of <br /> soil were removed from under the tank pit area. PHSIEHD would like to see the <br /> A Division of San Joaquin Counry Health Care Services <br />