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ENVIROI`�MENTAL HEALTHMEPARTMENT
<br /> °utry SAN JOAQUIN COUNTY
<br /> Q_. ., •,, Donna K.Heran,R.E.H.S. Unit Supervisors
<br /> Director 304 East Weber Avenue, Third Floor Carl 13orgman,R.E.H.S.
<br /> Al Olsen,R.E.H.S. Stockton, California 95202-2708 Mike Huggins,R.E.H.S.,R.D.I.
<br /> cgC
<br /> Douglas W.Wilson,R.E.H.S.Program Manager Man ax: (
<br /> Telephone: (209) 468-3420 Margaret Lagorio,R.E.H.S.
<br /> Laurie A.CotR.E.H.S. F209) 464-0138 Robert McClellan,R.E.H.S.
<br /> Program Manager Mark Barcellos,R.E.H.S.
<br /> RAY BAGLIETTO & FRANK RAUZI MAY 1 8 2005
<br /> TULEBURGE WAREHOUSE
<br /> 301 AURORA ST
<br /> STOCKTON CA 95202
<br /> RE: SPEEDY FOOD NL-\RT
<br /> 8200 N HWY 99
<br /> STOCKTON CA 95212
<br /> San Joaquin County Environmental Health Department(EHD) has received a letter dated May 3,2005 from
<br /> your consultant,Ground Zero analysis,Inc. (Ground Zero). Ground Zero stated that it is unclear as to what
<br /> EHD requires to determine if there is any pumping influence and potential draw down of the contaminants
<br /> (NfTBE) by the existing private drinking water well(PDXX] on the shallower groundwater aquifer Zone C,
<br /> which has already been impacted by dissolved contaminants.
<br /> In a meeting at San Joaquin District Attorney's office on November 30,2004,EHD stated that the pump test
<br /> as proposed in the November 12 2004 work plan,which calls for pumping from MW-13C screened from 202
<br /> to 222 feet below surface grade (bsg),at a rate of 3 gallons per minute (gpm) for 8 to 10 hours to test for
<br /> hydraulic communication with the deeper PDW which draws from approximately 330 feet bsg,is not likely to
<br /> work since there is a vertical distance of more than a hundred feet between the bottom of the i\1R1-13C screen
<br /> and the top of the screen on the private drinking well. As proposed,.eater would have to move against gravity
<br /> rather than with gravity as would be the case when the PDW is pumping. El ID suggested at the meeting that
<br /> level loggers should be placed in nearby wells in all 3 zones to begin collecting data 1 or 2 days before the pump
<br /> test to characterize natural water level fluctuations,then pumping from the PDW at a moderate rate,and
<br /> continue the DTV monitoring for lday after the pump test. In the work plan dated December G,2004,
<br /> Ground Zero proposed pumping from the PDW at a rate of 20 gpm for a period of 48 hours in addition to a 4-
<br /> hour step test at rates between 10 gpm and 30 gpm. Both EHD and Central Valley Regional Nater Quality
<br /> Control Board (RWQCB)did not agree with the second proposal since the high rate of pumping and total
<br /> volume of produced water may negatively impact the contamination plume by pulling down the contaminants
<br /> to a deeper aquifer. EHD also did not agree with the need for a step test since the objective is not to evaluate
<br /> the sustainability of pumping rates.
<br /> EHD contends a less aggressive approach to characterizing the hydraulic communication between the two
<br /> zones is in order. EHD requests you to have your consultant Ground Zero design a test that would effectively
<br /> evaluate the hydraulic condition of the two zones while minimizing the potential of pulling down the
<br /> contaminants. The objective of the directive is a qualitative assessment of the effect of pumping form the
<br /> PDW to evaluate the potential for the PDW to influence the plume,thereby causing vertical migration of the
<br /> plume and potentially impacting the PDW itself. If the well exerts a discernable influence on the plume,then
<br /> proper measures can be taken to effectively monitor the plume and design a plume management scheme to
<br /> protect the PDW and deeper groundwater suppfies. Submit this proposal to EHD by June 25,2005. f�A
<br /> Donna Heran,RENS,Director
<br /> Environmental Health Department
<br /> Jeffrey Wong,Senior RENS Nuel C. Ilenderson,Jr.,PG
<br /> LOP/Site Nfitigation Unit.IV LOP/Site!\litigation Unit IV
<br /> Cc: CRWQCB,Central Valley Region—James L.L.Barton,PG
<br /> Cc: Ground Zero Analysis,Inc.—John P.Lane,PG
<br /> Cc: San Joaquin County Deputy District Attorney—David Irey
<br /> Cc: Freeman,D'Aiuto,Pierce,Gurev,Keeling&Wolf—Lee Roy Pierce,Jr.,JD,\IBA
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