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PUBLIC MEALTH SERVICES Q�,N <br /> SAN JOAQUIN COUNTY <br /> z� <br /> ENVIRONMENTAL HEALTH DIVISION w , <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 °4i;Foa411P <br /> 209/468-3420 EC (DJ l <br /> JAMES GIOTTONINI MAILED MAR 0 819966- <br /> PUBLIC WORKS DIRECTOR <br /> CITY OF STOCKTON <br /> 425 NORTH EL DORADO STREET <br /> STOCKTON CA 95202 <br /> RE: 110 WEST SONORA STREET SITE CODE: 1253 <br /> STOCKTON CA <br /> During a recent telephone conversation between City of Stockton and San Joaquin County Public <br /> Health Services, Environmental Health Division (PHS-EHD) staff, the recent guidance from the State <br /> Water Resources Control Board (SWRCB) to agencies overseeing the investigation and cleanup of <br /> underground storage tank release sites was discussed. The following comments are being offered for <br /> your consideration. <br /> The possible changes mentioned in the December 8, 1995 guidance letter from the SWRCB are still <br /> unknown at this time. It can be expected, though, that any changes made to current laws or policies <br /> governing petroleum cleanups will likely not become effective until some time in early 1997. The <br /> guidance letter from the SWRCB recommends monitoring in this interim period for low risk plumes and <br /> that good judgement should be used when making these decisions. This guidance letter was based on <br /> the conclusions and recommendations of the Lawrence Livermore National Laboratory Report. This <br /> report concludes that in cases where the source has been removed passive bioremediation should be <br /> considered the primary remediation tool. 7 <br /> Current law requires an evaluation of the cost effectiveness of the remedial alternatives being <br /> considered for a site, including the alternative of passive bioremediation or natural degradation, be <br /> performed. The most cost effective approach that will achieve targeted cleanup goals must be utilized <br /> at the site. Targeted cleanup goals, however, is one of the issues currently under debate at the State <br /> level. <br /> For this site, PNS-EHD does not recommend to monitor only during this interim period but to proceed <br /> with the source removal as originally proposed. However, should the City of Stockton choose this <br /> interim alternative, the site will still maintain compliance with this agency. Under current conditions <br /> and unless major changes are made to State policies and/or laws, PHS-EHD cannot offer a site <br /> closure in any reasonable time using a passive remedial approach without source removal. In any <br /> event, PHS-EHD recommends the following site specific factors be considered when determining the <br /> final course of action to be taken at this site. <br /> The groundwater basin in this area is utilized heavily for municipal, industrial and agricultural <br /> uses. The use of our groundwater basin is expected to increase in the future due to continued <br /> urbanization in this area. Because our groundwater basin is so heavily used and other sources <br /> of water (surface water) are scarce, it is considered a valuable resource and is vigorously <br /> protected. For this site, current uses are not affected by the plume. However, future uses of <br /> this groundwater are unknown, cannot be adequately predicted, and may not be protected. <br /> PNS-EHD anticipates that any changes at the State level will continue to allow for current and <br /> future protection of valuable groundwater basins. <br /> I <br /> A Division of San Joaquin County Heaith Care Services <br />