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i <br /> PUBLIC AkALTH SERVItES <br /> SAN JOAQUIN COUNTY i <br /> ENVIRONMENTAL HEALTH DIVISION " ` `` <br /> Karen Furst, M.D., M.P.H., Health Officer � <br /> 304 East Weber Avenue, Third Floor • Stockton, CA 9520 - FOR <br /> ti <br /> 209/468-3420 <br /> PAUL SUPPLE JAN 0 610 <br /> ARCO PRODUCTS COMPANY <br /> PO BOX 6549 <br /> MORAGA CA 94570 <br /> RE: ARCO Station #548 SITE CODE: 1121 <br /> 1612 Hammer Lane <br /> Stockton CA <br /> San Joaquin County,Public Health Services Environmental Health Division (PHS/EHD) has <br /> recently reviewed the compliance status of the referenced site and has prepared the following <br /> comments for your response. <br /> The results included in the most recently submitted report prepared by EMCON"Quarterly <br /> Groundwater Monitoring Report,Third Quarter 1997" dated November 11, 1997,continued <br /> to evidence significant petroleum hydrocarbon and methyl tertiary butyl ether contamination, <br /> which has not been defined laterally or vertically. <br /> PHS/EHD has requested on numerous occasions that the field sampling sheets be included <br /> within the quarterly reports. All quarterly reports shall include field sampling sheets rather <br /> than a copy of the standard sampling and analysis procedures. PHS/EHD also has directed <br /> ARCO to analyze all groundwater samples using EPA Method 8260 for the target oxygenates. <br /> Groundwater samples collected in the future shall undergo EPA Method 8260, EPA Method <br /> 8020 and EPA Method 8015 M. <br /> PHS/EHD has directed ARCO to submit a work plan to define the extent of soil and <br /> groundwater contamination. PHS/EHD has been informed that offsite access was posing <br /> difficulties and that efforts were underway to obtain the property owner's permission. <br /> PHS/EHD has received from the property owner a copy of the revised draft access agreement <br /> dated December 12, 1997. Any appendixes referenced therein were not included in the faxed <br /> transmission which PHS/EHD received. <br /> PHS/EHD has not received a work plan to complete the investigation pursuant to the Health <br /> and Safety Code and the Underground Storage Tank Regulations. PHS/EHD did receive a copy <br /> of the April 24, 1997 "Authorization to Install Three Monitoring Wells at 1704 Hammer Lane" <br /> addressed to Wilbur Smith representing the property owner, Lincoln Properties, Ltd. PHS/EHD <br /> has been informed that there have been some general discussions between Lincoln Properties <br /> and ARCO regarding the scope of the off site investigation. It would appear that access should <br /> be granted;however,PHS/EHD has some concerns regarding the scope of appendix A - <br /> permitted activities referenced in the revised draft access agreement. <br /> Please note that ARCO shall submit by January 30, 1998, a work plan to complete the on site <br /> and off site investigation to determine the vertical and lateral extent of the contamination <br /> which resulted from the operation of underground storage tanks, to avoid further <br /> enforcement actions. The on site work shall be completed within 30 days of PHS/EHD work <br /> plan approval and the off site work shall be completed within 30 days of PHS/EHD work <br /> plan approval and following approval by the affected off site property owner. <br /> A Division of San Joaquin County Health Care Services <br />