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r <br /> San Joaquin County DIRECTOR <br /> Donna Heran, REHS <br /> Environmental Health Department�,•� �� •.p p ASSISTANT DIRECTOR <br /> 600 East Main Street Laurie Cotulla,REHS <br /> s :{ Stockton, California 95202-3029 PROGRAM COORDINATORS <br /> • Mike Huggins, REHS,RDI <br /> Website: www.s� eMargaret Lagorio,REHS <br /> ov.or / hd <br /> ��/FORS Jg g Robert McClellon,REHS <br /> Phone: (209)468-3420 .teff Carruesco,REHS,RDI <br /> Fax: (209)464-0138 Kasey Foley,REHS <br /> 01 July 2009 <br /> Ms. Yvonne Miller <br /> A R and M E Glover Trs <br /> Fayette Manufacturing Corporation <br /> P.O. Box 336 <br /> Tracy CA 95378 <br /> Subject: Fayette Manufacturing Corporation <br /> 7675 Eleventh Street <br /> Tracy, California <br /> The San Joaquin County Environmental Health Department (EHD) has reviewed Work Plan to <br /> Conduct Pilot Testing and Additional Subsurface Investigation Activities (WP), dated 16 <br /> February 2009, prepared by your consultant ATC Associates, Inc. (ATC) for the above <br /> referenced site. ATC proposes to install three dual phase extraction (DPE) wells, two additional <br /> groundwater monitoring wells and two air/ozone sparge wells to complete the delineation of <br /> impacted soil and groundwater and to pilot test high vacuum DPE (HVDPE) and air/ozone <br /> sparging (AS/OS); in addition, ATC proposes to collect soil and groundwater samples to bench- <br /> scale test ozone injection to evaluate the overall efficacy of the method, and to check for the <br /> generation and persistence of hazardous byproducts. <br /> The additional groundwater monitoring wells are proposed to complete the delineation of <br /> impacted soil and groundwater toward the east and apparently to refine the delineation in an <br /> open area toward the north-northwest. One of the three DPE wells is to be the test extraction <br /> well; the other two are to be DPE test monitoring wells. ATC has proposed to field test HVDPE <br /> and AS/OS to reduce contaminant mass in soil and groundwater and thereby reduce the cancer <br /> risk and health hazard to acceptable levels for site closure consideration. <br /> ATC proposes to present the findings from the proposed investigation in a report of findings and <br /> will also prepare a site conceptual model (SCM) and corrective action plan (CAP). <br /> With the exception of proposed monitoring well MW-9, the EHD approves the proposed scope <br /> of work as necessary and adequate at this time {H&S Code 25296.10(c)(3)1; the EHD does not <br /> believe that proposed monitoring well MW-9 is necessary at this time as the lateral extent of <br /> impacted soil toward the north-northwest appears to be adequately demonstrated with existing <br /> data and the existing monitoring well network adequately covers the area. The EHD <br /> recommends the following: <br /> • Vary the distances of the observation DPE wells from the test DPE well. <br /> • Impacted groundwater appears to be limited to the surficial fine-grained soil and the <br /> sand commonly encountered between 15 and 20 feet below surface grade (bsg); <br /> therefore the EHD recommends that the DPE test well be limited in depth to the same <br /> Work Plan Comment Letter 0709 <br />