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MEMORANDUMO <br /> CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD - CENTRAL VALLEY REGION <br /> 3443 Routier Road, Suite A Phone: (916) 361-5600 <br /> Sacramento, CA 95827-3098 ATSS Phone: 8-495-5600 <br /> TO: Antonia Vorster FROM: Richard McHenry <br /> Senior Engineer Area Engineer <br /> DATE: 18 May 1990 SIGNATURE: u ti <br /> SUBJECT: PHASE II SAMPLING WORK PLAN FOR LINCOLN VILLAGE CENTER, SAN JOAQUIN COUNTY <br /> Leedshill-Herkenhoff, Inc. has submitted revisions tc the Phase II work plan for <br /> Lincoln Village Center. The revisions dated 11 April 1990 are the third attempt at <br /> developing an acceptable work plan. Our comment letters dated 21 December 1989 and <br /> 27 March 1990 should be reviewed for specific detail . My comments on the revised work <br /> plan are as follows: <br /> 1. We required that monthly water level contour maps be included in the sampling <br /> plan. Leedshill-Herkenhoff (LH) submitted three quarterly maps and a map for <br /> March 1990. The maps which were submitted are of poor reproduction quality and <br /> barely legible. LH had previously submitted their raw water level data which they <br /> conclude is sufficient to show a consistent northeast direction of ground water <br /> flow. Ground water gradient maps are required to predict migration of the <br /> pollution plume and determine if local events, such as the pumping of nearby wells <br /> change the gradient. Sampling data must be included as an appendage to reports <br /> and acceptable methodology for interpretation of the data must be presented in the <br /> body of the report. <br /> 2. All water samples shall be analyzed for EPA 601 compounds not just PCE. PCE is <br /> currently the main focus of the ground water and soil investigation, however, this <br /> could change as PCE degrades to its breakdown products. LH has proposed that only <br /> downgradient wells be sampled for 601 compounds; this is an unacceptable <br /> alternative. All soil samples shall be analyzed for EPA 8010 compounds not just <br /> PCE. <br /> 3. LH has proposed the installation of eight new monitoring wells: <br /> A. Two deep wells to address vertical migration and define the deeper geology. <br /> The LVMD wells which show levels of PCE are screened deeper than the proposed <br /> monitoring wells. The two deep wells are not likely to define the vertical <br /> extent of pollution at the site but provide intermediate sampling and a <br /> better picture of deeper migration. Screens will have to be placed based on <br /> lithology encountered during drilling. <br /> B. Three shallow wells along Pacific Avenue established that the pollution has <br /> not left the property on its eastern border. At this stage of the <br /> investigation there is no evidence that the plume has extended to this point, <br /> however, Lincoln Village wishes to establish a perimeter monitoring network. <br /> There is evidence that pollution is off-site to the west of the site near <br /> MW-4 with no current plans for investigation. This is unacceptable. <br />