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P. 5 <br /> Andrew Bema-Hicks <br /> Page 2 of 2 <br /> February 18, 2003 <br /> INTRODUCTION <br /> On November 20, 2002, General Dynamics submitted a report written by Chow Engineering, titled <br /> "November 2002, Corrective Studies Measures, Solid Waste Management Unit No. 21, Follow Up <br /> Report,"(Follow Up Report), The Follow Up Report described the field methodology and analytical <br /> results of an April 2002 investigation at the facility, and recommended additional work to delineate <br /> the horizontal and vertical extent of petroleum hydrocarbons in the vicinity of SWMU #21. In a <br /> memorandum dated January 7, 2003, GSU concurred with the Follow Up Report while <br /> recommending some minor alterations, primarily with the intent of clarifying the planned field work. <br /> Subsequently, General Dynamics submitted the current Workplan, dated January-31, 2003, <br /> addressing the recommendations made by GSU. <br /> COMMENTS AND RECOMMENDATIONS <br /> GSU concurs with the current Workplan as written,with the exception of the proposed methodology <br /> for collecting a grab groundwater sample adjacent to boring BH-4. Although GSU concurred with <br /> the initial groundwater sample collection methodology proposed in the Follow Up Report, General <br /> Dynamics subsequently changed the groundwater sample collection methodology in the text of the <br /> current Workplan. In the November 2002 Follow Up Report,General Dynamics proposed to collect <br /> a grab groundwater sample from an 8-inch temporary boring. In the text of the current workplan, <br /> General Dynamics proposes to collect a grab groundwater sample by installing a temporary well <br /> using two-inch schedule 40 polyvinyl chloride (PVC) plastic, a filter pack, and an annular seal <br /> consisting of two feet of hydrated bentonite pellets, and then destroying the well. In Appendix B-2 of <br /> the current Workplan, however, a more traditional approach for collecting a grab groundwater <br /> sample through a temporary boring is described. In a subsequent telephone discussion between <br /> GSU and Chow Engineering on February 14, 2003, Chow Engineering explained that they were <br /> proposing to install a temporary monitoring well instead of collecting a more traditional grab <br /> groundwater sample in order to address concerns expressed by the San Joaquin County- <br /> Environmental Health Department. After additional discussion between GSU and the San Joaquin <br /> County-Environmental Health Department, as well as GSU and Chow Engineering, all parties <br /> concerned agreed that it is appropriate at this site to collect a grab groundwater sample by installing <br /> -a emporarylToflng as desenloeclin Appendix B-2 of the curve or an ra er than by installing a <br /> temporary we . enera ynamics s ou a aware, owever, wa i the boring is not immediately <br /> and properly abandoned following the collection of the grab groundwater sample,the San Joaquin <br /> County-Environmental Health Department will view the boring as an inadequately installed <br /> monitoring well and thus not in compliance with San Joaquin County well regulations. <br /> General Dynamics has adequately described the additional investigative work planned for the <br /> facility, and GSU concurs with the proposed field investigation. Thus, further workplan submittals <br /> are not required at this time and GSU recommends that the field work take place on March C>�� <br /> of2003, as scheduled. <br />