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STATE of CALIFORNIA-Environmental Protection Agency PETE WILSON Govemor <br /> CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD <br /> CENTRAL VALLEY REGION "`"`"°+� <br /> Router Road,Suite A Exi z � r A ` <br /> FFW <br /> mento,CA 95827-3098 <br /> E (916)255-3000 <br /> FAX (916)255-3015 <br /> 8 November 1995 <br /> Mr John Welch <br /> Attorney at Law <br /> 3620 West Hammer Lane, Suite B <br /> Stockton, CA 95219 <br /> WORK PLAN FOR ADDITIONAL INVESTIGATION, INDEPENDENT TRUCKING <br /> FACILITY, 1145 WEST CHARTER WAY, STOCKTON, SAN JOAQUIN COUNTY <br /> We have reviewed the 11 October 1995 Work Plan for Additional Site Investigation submitted by Wm J <br /> Hunter & Associates for the 1145 West Charter Way site in Stockton We have added Mr Hunter to our <br /> distribution last <br /> The scope of the work plan is too limited and needs more details Mr Hunter stated that because of the <br /> short time frame which he had to prepare a work plan, more complete details will follow as soon as <br /> qualified vendors and service companies have been selected Preparation of a detailed and complete work <br /> plan to do investigative work should not be dependent upon the selection of subcontractors to do the <br /> approved work Even though you did not receive the Board's 13 September 1995 letter until 27 <br /> September, there were stall two and a half weeks to prepare an acceptable work plan In addition, as you <br /> know, we will grant reasonable extensions upon request <br /> The work plan states that geophysical methods will be utilized to locate possible underground sources of <br /> contamination This is appropriate although the work plan needs to describe in detail exactly what is <br /> going to be done We suggest also using air photos to aid in this investigative work A survey of <br /> neighboring businesses also would be appropriate to study the potential off-site sources of contamination <br /> which may be affecting the site <br /> Your proposal to obtain soil and ground water samples using a geoprobe-type technique is appropriate <br /> although the work plan should show in a figure the specific sampling locations and describe the sampling <br /> protocol Mr Hunter states that the locations of soil borings and "potential" monitoring wells cannot be _ <br /> determined until after the geophysical work is complete We disagree with this Since we are trying to <br /> define the current extent of contamination in the soil and ground water, the existence of ongoing sources <br /> will have no mayor bearing on the placement of borings and monitoring wells over the time frame of the <br /> work plan In addition, more monitoring wells definitely are needed to fully define the extent of ground <br /> water contamination <br /> By S December 1995, you are required to submit a detailed work plan to define the full lateral and <br /> vertical extent of soil and ground water contamination The work plan shall include a proposal to <br />