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SITE INFORMATION AND CORRESPONDENCE
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EHD Program Facility Records by Street Name
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99 (STATE ROUTE 99)
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5708
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3000 – Underground Injection Control Program
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PR0522753
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SITE INFORMATION AND CORRESPONDENCE
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Last modified
11/19/2024 1:57:04 PM
Creation date
4/30/2020 2:17:00 PM
Metadata
Fields
Template:
EHD - Public
ProgramCode
3000 – Underground Injection Control Program
File Section
SITE INFORMATION AND CORRESPONDENCE
RECORD_ID
PR0522753
PE
3030
FACILITY_ID
FA0015509
FACILITY_NAME
ST FRANCIS MOTEL
STREET_NUMBER
5708
Direction
N
STREET_NAME
STATE ROUTE 99
City
STOCKTON
Zip
95212
APN
08703013
CURRENT_STATUS
01
SITE_LOCATION
5708 N HWY 99
P_LOCATION
99
P_DISTRICT
003
QC Status
Approved
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EHD - Public
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High TECh ENTERPRISES <br /> motel's water well. Unfortunately,the owners of the motel did not fully understand your re- <br /> quirement and proceeded to have the water in the well analyzed by Precision Enviro-Tech Ana- <br /> lytical Laboratory, a local certified analytical laboratory. This action was undertaken in good <br /> faith by the Saint Francis Motel in hopes of finally putting this matter to rest. <br /> 8. In late October, 2004,the owners of the Saint Francis Motel asked me to review the lab results of <br /> Precision Enviro-Tech Analytical Laboratory's analyses of the water well, and I did this,provid- <br /> ing my conclusions in High Tech Enterprises Report#041001-L-F A copy of this report too <br /> was forwarded to your office. Since every chemical analyzed in this lab effort was shown to be <br /> either"non-detect" or"zero," it was not too difficult for me to conclude that the water well <br /> contained no hazardous chemicals, and was,therefore,totally safe to drink or to use in any other <br /> manner without causing any health hazard to a person who might come into contact with this <br /> water. <br /> 9. After receiving the copy of this report,your department demanded that the Saint Francis Motel <br /> further contract to have a certified geologist—or a person with equivalent credentials—evaluate <br /> the subterranean hydrologic flow path, flow rate,etc.to be able to ensure that the organic chemi- <br /> cals in the septic tank could not migrate to the water well. <br /> I believe that this is an accurate characterization of the chronology. <br /> I would now like to add a number of my own comments. First of all,I have included with this memo <br /> a copy of my Resume in order for you and/or your department to understand how my own qualifica- <br /> tions are sufficient for me to render certain judgments in this matter. Please note, I hold credentials as <br /> a Professional Engineer, a Certified Industrial Hygienist, a Certified Safety Professional, and a Quali- <br /> fied Environmental Professional. As you can see from this Resume,I have been involved in these <br /> fields for well over two decades. <br /> During our conversation of 1 December 2004,I informed you that the combination of my education, <br /> my experience,and my credentials was NOT sufficient to allow me to provide opinions on the subter- <br /> ranean hydrologic matters over which your office has expressed so very much concern. I believe, <br /> however,that I am able and qualified to provide ALL of the following opinions. <br /> 1. The volume of organic chemicals in the septic tank was INSIGNIFICANT—equivalent to just <br /> over 35.5 drops (i.e., as from an eye dropper)of these five organic chemicals in a tank containing <br /> approximately 600 gallons of septic fluids. On this same basis, 600 gallons of septic fluids is <br /> equivalent to just over 148,000,000 drops (i.e., as from an eye dropper). My opinion was that <br /> this level of organics was, as stated above and in the previously referenced High Tech Enter- <br /> prises Report#040501-L-F, INSIGNIFICANT. In my judgment, the situation required no ad- <br /> ditional remediation whatsoever. I believe that my professional qualifications are such that your <br /> department MUST consider this opinion to be valid. <br /> 2. Additionally,the septic tank no longer contains any "organic chemicals" (since its contents have <br /> been pumped). It is my opinion,therefore,that even if the contents of the septic tank are able to <br /> migrate to the water well—obviously,under favorable subterranean hydrologic conditions—that <br /> there is still no chemical hazard from such a migration. To stress again, there are no dangerous <br /> organic chemicals remaining in the septic tank. This too is an opinion that I believe your de- <br /> partment must credit as being valid, again based upon my professional qualifications. <br /> 3. Finally, I note that the Saint Francis Motel's water well is located approximately 260 feet WSW <br /> of the motel's septic tank,although I have no opinion as to the hydrologic distance between these <br /> two facilities. I note further that the well is approximately 30 feet east of an asphalt paved road- <br /> way. If there were to have been any organic impurities in this well,I would have expected that <br /> they would most likely be leachates of the shorter hydrocarbon chain members of a standard as- <br /> phaltic matrix. Since there were no such hydrocarbons identified as being in the well, it is clear <br /> that these asphaltic leachates have not migrated east 30 feet into the water well. Since the con- <br /> centration of these alphaltic hydrocarbons is orders of magnitude greater than the measured con- <br /> centration levels of organic chemicals that used to be in the septic tank, and since the distance <br /> between the roadway and the water well is just over 10%of the separation between the water well <br />
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