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San Joaquin County <br /> Environmental Health Department DIRECTOR <br /> Donna Heran,REHS <br /> 2: 1868 East Hazelton Avenue <br /> Stockton, California 95205-6232 PROGRAM COORDINATORS <br /> Robert McClellon, REHS <br /> Jeff Carruesco, REHS, RDI <br /> meq' •.....• ' �P Website: www.sjgov.org/ehd Kasey Foley,REHS <br /> - Linda Turkatte, REHS <br /> Phone: 209 <br /> ( ) 4683420 Rodney Estrada,REHS <br /> Fax: (209) 464-0138 Adrienne Ellsaesser, REHS <br /> October 15, 2014 <br /> Charan Singh Dhillon Etal Aurangzeb (Zeb) Khan <br /> 2057 South EI Dorado Street 3128 Jasper Avenue <br /> Stockton, CA 95206 Modesto, CA 95350 <br /> LOP Site: Quick-N-Save <br /> 2057 South EI Dorado <br /> Stockton, CA 95206 <br /> Subject: Failure to Inform the Environmental Health Department of Changes to <br /> Groundwater Sampling and Remediation Events and Proper Sampling <br /> Protocols <br /> The San Joaquin County Environmental Health Department (EHD) must address concerns with <br /> you regarding scheduling of groundwater sampling events and proper sampling protocols that <br /> should be followed during monitoring events. To minimize differences in data derived from <br /> changes of consultants, field personnel, laboratories, etc., the EHD has issued groundwater <br /> sampling guidelines that reflect the guidelines published by the California State Water resources <br /> Control Board (SWRCB) in the Leaking Underground Fuel Tank Guidance Manual (LUFT <br /> Manual) issued in 2012, portions of which are attached for your reference. By minimizing <br /> variations in data obtained by different field personnel or consultants, the data obtained by one <br /> can be utilized by subsequent workers, thereby preserving the value of previously obtained <br /> data. <br /> The EHD plays a role in ensuring that reliable data is obtained from field work by observing the <br /> work in progress to verify proper equipment and procedures are utilized to obtain samples; the <br /> LUFT Manual referring to site assessment work, makes the following statement (page 15-6).- <br /> "An <br /> 5-6):"An inspector from the lead agency or local oversight agency which has issued a specific permit <br /> has the authority to be present during site work, unless prior approval to proceed without an <br /> inspector onsite has been obtained" and `The agency has the regulatory authority to reject <br /> analytical or field results obtained during field work if the proper inspection arrangements have <br /> not been made and there is a reasonable suspicion that the data are not valid."The EHD is of <br /> the opinion that the same principle holds for groundwater monitoring events, and the EHD is not <br /> aware of any oversight agency that does not require advance notice of groundwater monitoring <br /> events. There have been several recent instances of failures to inform the EHD of changes in <br /> scheduled monitoring events that have deprived the EHD of the opportunity to observe the <br /> monitoring and sampling processes at your Local Oversight Program (LOP) site. Despite <br /> reminders that the EHD should be notified of such scheduling changes, failure to notify the EHD <br /> has been repeated, taking on the appearance of evasiveness, which has the EHD concerned. <br /> EHD was informed that a groundwater sampling event was to take place on July 17, 2014, but <br /> no one was present at your LOP site to perform the work site at the appointed tirne when the <br /> EHD representative arrived. EHD was informed by a field technician by phone that the <br />