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Failure to comply with the directives above may result in referral to the San Joaquin County District <br /> Attorneys Office. <br /> The data sets above were requested in order to estimate and evaluate plume migration and health risk <br /> potentials. In addition, the data gathered was to be used when necessary to inform the appropriate <br /> agency(s) and consumer(s) of predicted, potential or known impacts by contaminants and any related <br /> health risks regarding this beneficial use aquifer. <br /> PHS/EHD has received and reviewed a revised monitoring well design and placement work plan from the <br /> responsible party's consultant REE dated June 22, 1998. This work plan was rejected for three principal <br /> reasons. <br /> First, no formal report of findings from the May 1998 cone penetration tests(CPT)have been submitted to <br /> this agency for the above referenced site as required in previous PHS/EHD correspondence (no cross <br /> sections, no descriptions of site specific/regional hydrogeology, no tabulated analytical data, no <br /> recommendations, no conclusions or certification signatures by qualified professionals have been <br /> submitted to PHS/EHD). Second, incomplete data sets from the recent tank removal have been received by <br /> PHS/EHD. Both of these data sets are critical to efficient and cost effective placement/construction of bore <br /> holes and monitor wells. <br /> Third,the revised work plan proposal fails to apply appropriate strategies to adequately define the extent of <br /> known contaminant distribution in ground water and soil or the potential for contaminants to migrate to <br /> drinking water supplies at and in the vicinity of the above referenced site. The work plan proposal fails to <br /> further characterize documented contaminant presence, Methyl Tertiary Butyl Ether (MTBE) at 75 foot <br /> below grade surface observed nearest the on-site public water system wellhead and Tetrachloroethylene <br /> (PCE)near the former waste oil tank. The work plan also fails to reference monitor well head elevations to <br /> a registered survey benchmark. The proposed well construction details indicate that the screen intervals for <br /> monitor wells will not coincide with known similar hydrogeologic intervals which may result in inaccurate <br /> gradient determinations and possibly create conduits to deeper portions of the aquifer by bridging <br /> significantly different lithologic units. <br /> In order to protect public health, safety and the environment, and control costs for generating <br /> numerous revisions in work plans, PHS/EHD technical staff direct the responsible party and their <br /> consultant to schedule a meeting with this agency to discuss potential revisions to the most current <br /> workplan. This meeting shall be completed no later than September 25,1998. <br /> Please submit technical reports to the San Joaquin County Public Health Services Environmental Health <br /> Division(PHS/EHD),Attention: Ron Rowe. <br /> Should you have questions regarding this correspondence please contact Ron Rowe at(209)468-0342. <br /> Donna Heran,REHS,Director <br /> Environmental Health Division <br /> Rotw ka� <br /> we, Sr.REHS Margaret gorio,Supervisor <br /> Site Mitigation Unit Site Mitigation Unit <br /> CC: San Joaquin County District Attorney's Office Environmental Prosecution Unit- <br /> David Irey <br /> PHS/EHD UST Unit-Doug Wilson <br /> PHS/EHD Water Systems Unit-Ray Borges <br /> CVRWQCB—Mark List <br /> 2072enf3.doc <br /> 2 <br />