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PUBLIC EtALTH SERVIES <br />SAN JOAQUIN COUNTY <br />ENVIRONMENTAL HEALTH DIVISION <br />Karen Furst, M.D., M.P.H., Health Officer <br />304 East Weber Avenue, Third Floor • Stockton, CA 95202 <br />209/468-3420 <br />DONNA SANTINI GARDNER <br />1206 STRUCK <br />ORANGE CA 92667 <br />RE: Donna Gardner Property <br />26056/26080 Thornton Road <br />Thornton CA 95686 <br />SEP 2 2 1997 <br />Site Code: 1864 <br />San Joaquin County Public Health Services, Environmental-Health Division (PHS/EHD) has reviewed <br />the "Problem Assessment Report - Interim Remedial Plan" dated September 4, 1997 which was prepared <br />by Smith Environmental Technologies. PHS/EHD has the following comments for your consideration <br />and response. <br />The interim remedial plan (Plan) included the well construction information for the Thornton Municipal <br />Supply Well #2 (Supply Well) which is located 85 feet north of monitoring well, MW4. The Supply <br />Well is cased to a depth of 245 feet below ground surface (bgs) and perforated at three intervals <br />beginning at 135 feet bgs. A sanitary seal of the 30 inch conductor casing extends to 70 feet bgs. A field <br />inspection in 1982 by the California Department of Health Services indicated that the static groundwater <br />level was 34.9 feet bgs and that when the pump was in operation that the depth to water dropped to 77.4 <br />feet bgs. The Supply Well currently serves 264 connections in the Thornton area. <br />Following the 1995 excavation attempt which removed 1,400 cubic yards of contaminated soil, an <br />investigation was conducted to determine the extent of the remaining soil contamination. Soil <br />contamination is evidenced between 11 and 30 feet bgs and is estimated to extend to within 60 feet of <br />the Supply Well. During the excavation attempt 10,000 gallons of contaminated groundwater were <br />removed and remediated. Grab groundwater samples were collected during the subsequent investigation <br />beyond the existing monitored area. The groundwater plume is estimated to extent to within 30 feet of <br />the Supply Well. Please submit a corrected Table 1 which reflects the actual results as reported by the <br />laboratory for the soil samples during the November 1996 investigation and an amended Table 2 which <br />summarizes the grab groundwater analytical results obtained. <br />The Plan further evaluated remedial alternatives because contaminants remaining in the vadose and <br />saturated zones appear to threaten the mass reduction of dissolved petroleum hydrocarbons in the vicinity <br />of MW4 and because the close proximity of the dissolved petroleum hydrocarbon plume provides the <br />reasonable potential to impact the Supply Well's water quality, thereby potentially affecting the health of <br />the residents served by this well. Natural attenuation was considered initially, but was not <br />recommended due to the extent of remaining soil contamination and the proximity of the groundwater <br />plume to the Supply Well. Additionally, it must be noted that in 1985 the tanks, which were <br />subsequently removed in 1989, were considered abandoned. The site was last an active station sometime <br />prior to 1985. Further excavation was not recommended due to the presence of multiple utility lines <br />within the area of the remaining contamination. The Plan recommended that a pilot scale test of soil <br />vapor extraction and air sparge be implemented to determine the effectiveness of these remedial options. <br />The Plan proposed to install three vapor extraction wells, one air sparge well, and a sentinel monitoring <br />1 <br />A Division of San Joaquin County Health Care Services