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ENVIRONMENTAL HEALTH DEPARTMENT <br /> R.E.H.S.Heron <br /> Donna K. , SAN JOAQUIN COUNTY <br /> Unit Supervisors <br /> Director <br /> _ n '? <br /> 304 Easy Weber Avenue., Third Floor Carl Borgmaa, 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 /> Douglas W, Wilson, R.E.H.S. <br /> • C4C� FOR�`P • Program Manager Telephone: (209) 468-3420 Margaret Lagorio, R.E.H.S. <br /> Laurie A. Cotulla, R.E,H.S. Fax: (209) 464-0138 Robert McClellon, R.E.H.S. <br /> Program Manager Mark Barcellos, R.E.H.S. <br /> REMO CANEPA FEB 0 4 2003 <br /> CANEPA' S CAR WASH <br /> 1536 N HUNTER <br /> STOCKTON CA 95204 <br /> RE: CANEPA'S CAR WASH Site Code: 1225 <br /> 6230 PACIFIC AVENUE <br /> STOCKTON CA 95204 <br /> By letter dated October 2, 2002, Condor Earth Technologies, Inc. (CET) proposed destroying <br /> monitoring wells MW-8 and NAV-10, reducing the frequency of sampling of MW-5, MW-6, and <br /> MW-7 from quarterly to annual events, and begin analysis of groundwater samples from soil vapor <br /> extraction (SVE) well SV-4 on a quarterly basis. <br /> In a telephone conversation on January 17, 2003, San Joaquin County Environmental Health <br /> Department discussed with CET the various proposals. EHD has the following comments and <br /> conditions: <br /> 1) EHD does not agree with the destruction of MW-10 at this time. MW-10 is currently <br /> the furthest northwesterly sampling point at the site. MW-10 provides delineation of <br /> the zero concentration line and depth to groundwater measurement in the northwest <br /> direction. EHD will approve annual sampling with continued quarterly depth to water <br /> measurement if requested. <br /> 2) EHD requests you reinitiate testing for all 5 oxygenates, 1 ,2-dichoroethane (1 ,2-DCA), <br /> and ethylene dibromide (EDB) using EPA Method 8260B beginning with the next <br /> quarterly sampling event. Testing for oxygenates other than MTBE ceased in October <br /> 1999 at the request of the Underground Storage Tank Clean Up Fund (Fourth .Quarter <br /> 1999 GroundmaterMonitoring Report prepared by CET), and since then, MTBE has been <br /> analyzed using only EPA Method 8020. As tert-butyl-alcohol (TBA) may be a break- <br /> down product of MTBE and has a higher solubility and lower retardation factor than <br /> MTBE, with potential to advance even faster in groundwater, it is crucial that you restart <br /> analyzing for TBA and the other oxygenates using EPA Method 8260B. In a telephone <br /> conversation on February 3, 2003, the Clean Up Fund stated the cost of 8260 testing <br /> would be reimbursed if it was requested in writing in the pre-approval application. <br /> EHD requests that you seek pre-approval immediately so 8260 testing could begin the <br /> next quarterly sampling event. <br /> 3) The detection limit for TBA should be minimally set at or below the action level of 12 <br /> parts per billion (ppb) established by State Department of Health Services (DHS) . Also, <br /> MTBE concentrations in MW-2 exceeded 2000 µg/l in April and July of 2002, but have <br /> been reported as "non-detect" at detection limit of 2,000 µg/1. The detection limit for <br /> MTBE must be lowered at least to the DHS primary maximum contaminant level <br />