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"0.U 1 Iy <br /> �o.•T .c G <br /> COUNTY OF SAN JOAQUIN CNEF6DEPUTYDIRECTOR <br /> DEPARTMENT OF PUBLIC WORKS THOMAS R.FLINN <br /> P O BOX 1810- 1810 E RAMTON AVENUE DEPUTY DIRECTOR <br /> STOCKTON,CAUFORMA 95201 <br /> 4(•�F O•A'�\ (2091 468-3000 ANUEL LOPEZ <br /> DEPUTY DIRECTOR <br /> HENRY M. HIRATA <br /> DIRECTOR <br /> I 17 <br /> Z 1� t• <br /> February 5 , 1988 <br /> San Joaquin Local Health District <br /> Environmental Health Division <br /> P .O. Box 2009Stockton , Calrnia NVlt;, <br /> k1 HE <br /> Attn : Mr . JamesoMiller, Sanitarian 01 F RM" CES <br /> SUBJECT : USE PERMIT APPLICATION BY TERRA GENISIS FOR CONTAMINATED <br /> SOIL TREATMENT FACILITY NEAR PALM LANE AND STATE HIGHWAY 99 <br /> Dear Mr . Miller : <br /> This correspondence is in response to our telephone conversation <br /> of January 29, 1988 during which you indicated I should submit my <br /> comments to your office regarding subject project. Upon review <br /> of the project plans and description (See Attachment 1 ) , I have <br /> the following comments. <br /> 1 . ) The project description indicates contaminated <br /> soil will be spread on the slab to a depth of one to two feet. <br /> It also indicates that winter operation will have a treatment <br /> cycle of 10 to 14 weeks . <br /> With an open slab curbed one foot high and soils being processed <br /> during winter months , rainwater will probably build up and <br /> overflow in treatment area. Evaporation may not keep up with <br /> rainfall during heavy rains as the project engineer has <br /> indicated . <br /> If water builds up in the treatment area and overflows the curb <br /> it may leach to the groundwater which is only 8 feet deep at the <br /> project site . Since the collection system does not extend <br /> laterally beyond the edges of the slab it will not be able to <br /> intercept overflows from the treatment area . <br /> 2 . ) The project statement indicates soil samples will be <br /> analyzed for petroleum hydrocarbon content . However it does not <br /> indicate what regulatory agency standards will be used to <br /> determine acceptability for use of soils off site or what agency <br /> will determine designation of use . <br /> 3 . ) No mention is made of the closure or monitoring <br /> procedures for the site . Verification of no environmental <br /> degradation at the site should be performed before it is <br /> abandoned at a minimum. The State Departments of Health and <br /> Water Resources should be made aware of the project and current <br /> site conditions so that they may impose appropriate requirements <br /> on the treatment process and site design or designation of <br /> treated soils . <br />