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rr <br /> PUBLIC HEALTH SERVICES )0POU!N <br /> SAN JOAQUIN COUNTY r � c0c <br /> JOGI KHANNA M.D.M.P H <br /> Hench Officer <br /> P.O. Box 2009 • (1601 East Hazelton Avenue) • Stockton, California 95201 c9I(c oa��r <br /> (209) 468-3400 <br /> C \J Py <br /> RICHARD CALLISTRO <br /> SAN JOAQUIN COUNTY CAPITAL PROJECTS OCT <br /> '1 1 <br /> 222 E WEBER AV - RM 678 <br /> STOCKTON CA 95202 <br /> RE: San Joaquin County Human Services SITE CODE: 1257 <br /> 245 S. Sutter St <br /> The San Joaquin County Public Health Services, Environmental Health Division <br /> (PHS/EHD) has received your consultant's letter dated September 3, 1993 <br /> responding to specific issues related to PHS/EHD's correspondence dated August <br /> 18, 1993. <br /> In reference to Item #1, in the Weston letter, that the Tri-Regional document is <br /> a recommendation and not a requirement, the State Water Resources Control Board <br /> (SWRCB) adopted Resolution No. 92-49 "Policies and Procedures for Investigation <br /> and Cleanup and Abatement of Discharges Under Water Code Section 13304" on June <br /> 18, 1992. The Resolution states that "on or before July 1, 1992, the SWRCB shall <br /> establish policies and procedures that its representatives and the <br /> representatives of the RWQCBs (Regional Water Quality Control Board] shall follow <br /># for the oversight of investigations and cleanup and abatement activities <br /> resulting from discharge of hazardous substances". <br /> The Resolution outlines in formal format, regardless of the type of discharge, <br /> procedures and policies applicable to investigations, cleanup, and abatement <br /> activities. The Resolution is currently under review by the Office of <br /> Administrative Law for language clarification, however, the Resolution is <br /> supported by both the SWRCB and the RWQCBs. Furthermore, while the title of the <br /> Tri-Regional Board staff investigative manual might imply that the document is <br /> a recommendation, it directly reflects the intent of Resolution 92-49, the <br /> intent of the SWRCB, and the intent of PHS/EHD. <br /> PHS/EHD understands that WESTON will provide practical quantitative analytical <br /> results to future groundwater monitoring reports. If the Practical Quanitiation <br /> Limits (PQLs) are not achievable, an explanation of the problem associated with <br /> the sample analysis is to be submitted on the laboratory data sheets. <br /> In response to Item #2, WESTON's future reporting limits should rectify the <br /> concern with concentrations below the detection limits. It is extremely <br /> important to report quantitative data relative to groundwater degradation so that <br /> residual contaminants remaining in the soil and/or groundwater can be calculated, <br /> when relevent and appropriate, to determine potential or actual threat to water <br /> quality (i.e. , mass balance calculations) . Therefore, for site evaluation <br /> purposes, estimates at low concentrations do provide practical value. <br /> PHS/EHD has pledged to identify areas of potential "streamlining" . Item #3 can <br /> be accomplished with a reduction in the number of monitoring wells sampled and/or <br /> a modification in the analytical data at each quarterly event. PHS/EHD does not <br /> agree with the elimination of TPH-D, EDB, and Total Lead analyses in future <br /> monitoring events, but will agree to modifications which will continue to yield <br /> sufficient quantitative analysis. <br /> _{Division of San Joaquin Couno,HraLLh Cur mni<cs <br />