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e.✓ <br /> ENVIRONMENTAL HEALTH 16EPARTMENT <br /> PQ'U'�"••C SAN JOAQUIN COUNTY Unit Supervisors <br /> Third Floor Carl Borgman,R.E.H.S. <br /> "..A Donna K.Heran,R.E.H.S. 304 East Weber Avenue, Mike Huggins,R.E.H.S.,R.D.I. <br /> a Director Douglas W.Wilson,R.E.H.S. <br /> ' Al Olsen,R.E.H.S. Stockton, California 95202-2708 <br /> g Telephone: (209) 468-3420 Margaret Lagorio,R.E.II.S. <br /> • �. JP Program Manager Robert McClellon,R.E.H.S. <br /> FOR`' Laurie A.Cotulla,R.E.H.S. Fax: 209) 464-0138 <br /> ( Mark Barcellos,R.E.H.S. <br /> Program Manager <br /> VAR 10 2005 <br /> SONYA OLBRANTZ <br /> PREMDOR US HOLDINGS INC <br /> 105 W SWAN STE A <br /> PIEDMONT AL 36272 <br /> RE: Premdor SITE CODE: 0001329 <br /> 433 W. Scotts Ave. <br /> Stockton, CA <br /> San Joaquin County Environmental Health Department (EHD) has reviewed your <br /> letter dated February 7, 2005 and the "Additional Site Assessment Work Plan <br /> and Site Conceptual Model" (work plan) dated February 15, 2005, prepared by <br /> Advanced GeoEnvironmental, Inc. for the above referenced site. <br /> In your letter you request that the requirement for additional investigation be <br /> rescinded because it won't provide significant data for the expense and that you <br /> think the data indicates there is an upgradient source. There is both soil and <br /> groundwater data from the areas adjacent to and in the former underground <br /> storage tank (UST) locations to confirm that the contamination is from your site. <br /> EHD is not aware of any UST sites upgradient (southwest) and near your site. <br /> Monitoring well two (MW2) has consistently had contamination in the water <br /> samples collected from it and it is adjacent to one of the former UST locations. <br /> Differences in contaminant concentrations are common at UST site <br /> investigations because of the variations in depth to water, purging, water <br /> collection techniques and laboratory sample handling and analysis. Because <br /> groundwater gradients are low and groundwater flow directions change over time <br /> due to different influences it is common to have contamination that currently is in <br /> an upgradient direction. In addition, the groundwater flow direction at Sierra <br /> Lumber (adjacent to and north of your site) is southerly. Your site data is <br /> comparable and consistent with data from other UST contaminated sites with <br /> similar site conditions. Therefore, EHD is requiring you to investigate the lateral <br /> and vertical extent of soil and groundwater contamination from the former leaking <br /> UST's that were at your site. <br /> Revisions to the work plan submitted to further investigate the site should be <br /> considered. In order to have repeatable groundwater samples for investigating <br /> the extent of contamination upgradient, installation of a monitoring well instead of <br /> a soil boring in Lincoln Street should be evaluated. Also installation of a <br /> monitoring well (for repeatable water sampling) instead of a soil boring east <br />