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stool <br /> 2 . The second portion of this proposal, treatment of the <br /> contaminated soil by uncontrolled aeration is also a <br /> major concern. Due to the extremely high concentrations <br /> of aromatic and total hydrocarbons reported and the close <br /> proximity to the school and surrounding residences, <br /> public notice must be made to allow comment by <br /> potentially affected parties. This would be accomplished <br /> by direct notice to surrounding residents and school <br /> attendees, publication in the local newspaper and a <br /> public meeting. The requirement for public participation <br /> is contained in Federal Law (40CFR280. 67) and applies to <br /> all underground tank (UGT) clean up sites undergoing <br /> corrective action (remediation) . In addition, the <br /> contaminated soil storage and treatment area must be <br /> adequately secured to prevent unauthorized access and <br /> covered to limit the quantity of soil being aerated as <br /> required by San Joaquin County Air Pollution Control <br /> District (APCD) regulations. <br /> 3 . The EHD recommends that the districts limited resources <br /> be directed toward identification of the nature and <br /> extent of contamination with soil borings and groundwater <br /> monitoring wells prior to initiating soil excavation. <br /> The advantage to this approach would be the ability to <br /> plan and evaluate remediation option including whether <br /> excavation is feasible or necessary, whether other less <br /> disruptive techniques might be applied and whether the <br /> contamination is impacting groundwater. Exposure to the <br /> public, students and school personnel could be better <br /> controlled or eliminated. <br /> 4 . The School Distract at this time also has the option to <br /> request removal from the San Joaquin County Local <br /> Oversight Program (formerly Pilot Program) and do nothing <br /> further concerning investigation and remediation at this <br /> time. The site would continue to be listed on the San <br /> Joaquin County UGT contamination list and periodic <br /> reports on the status of the site would be required. The <br /> advantage to this approach is that District funds would <br /> not be spent on remediation and investigation and the per <br /> hour cost for regulatory oversight by the EHD would be <br /> lower after January 1, 1991. However, the School <br /> District would risk possible groundwater contamination, <br /> including the threat of contamination to the school water <br /> supply and/or surrounding wells. At a minimum the <br />