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I <br /> 'R ENVIRONMENTAL HEALTH DEPARTMENT <br /> ppUINSAN JOAQUIN COUNTY <br /> so �.coG Unit Supervisors <br /> Donna K.Heran,R.E.H.S. 304 East Weber Avenue, Third Floor Carl Borgman,R.E.H.S. <br /> �> DirectorMike Huggins,R.E.H.S.,R.D.I. <br /> Al Olsen,R.E.H.S. Stockton, California 95202-2708 Douglas W.Wilson,RTA.S. <br /> c4 `Foa? 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 ®p Robert McClellon,R.E.H.S. <br /> Program Manager °tlU Vi➢ 2 3 7(M#k Barcellos,R.E.H.S. <br /> GENE GABBARD INC JIM & SHEYLA CREEL <br /> 10335 CREEK TRAIL 640 EL DORADO ST <br /> STOCKTON CA 95209 STOCKTON CA 95202 <br /> RE: Gabbard Property SITE CODE: 1090 <br /> 640 EI Dorado Street <br /> Stockton CA 95202 <br /> San Joaquin County Environmental Health Department (SJC/EHD) has received a letter <br /> dated November 11, 2004, written on your behalf by Ground Zero Analysis, Inc. (Ground <br /> Zero), and has the following comments. <br /> The letter was written in response to the October 26, 2004 SJC/EHD directive to submit a <br /> work plan to complete the investigation of the vertical and lateral extent of the <br /> documented groundwater contamination at your site. The work plan is due for submittal <br /> no later than December 17,2004. <br /> Your consultant, Ground Zero, proposed, in the September 6, 2002 "Work Plan for Well <br /> Installation and Feasibility Study, Second Revision", to explore the vertical extent of the <br /> groundwater contamination at your site by collecting grab groundwater samples from <br /> deeper water bearing zones at locations away from the contaminated former tank pit area. <br /> Specifically, Ground Zero stated 'Two hydropunch groundwater samples will be collected <br /> from each boring...actual depths will be determined in the field". By failing to collect <br /> groundwater samples from a deeper water bearing zone, Ground Zero failed to achieve <br /> the objective of their proposed work plan, which was to investigate the vertical extent of <br /> the groundwater contamination. A work plan is a roadmap to achieve the investigation <br /> objectives; if necessary to achieve the objectives it is acceptable for the person in <br /> responsible charge of the investigation to modify the approved scope of work, utilizing <br /> data acquired during the fieldwork and good professional judgment. If modification of the <br /> approved work plan is not possible, than a work plan addendum should be submitted to <br /> complete the investigation. Therefore,the directive to determine the vertical extent of <br /> impacted groundwater,which you have been under since June 2, 1998, has not been met. <br /> Your continued disregard of this directive places you out of compliance with regulatory <br /> directives, which puts your eligibility for reimbursement from the California State Water <br /> Quality Control Board Cleanup Fund in jeopardy. <br /> Ground Zero discusses at length their review of the SJC/EHD file of a site located at <br /> 819 Hunter Street, which is two blocks north of and cross gradient to your site. The 819 <br /> Hunter site has been undergoing initial subsurface investigation and has documented soil <br /> contaminated by tetrachloroethlyene (PCE), one of the contaminants of concern in the <br /> groundwater at your site. PCE, and the breakdown products of PCE, are documented in <br /> the soil beneath the former tank pit at your site as well. While it is unlikely that the soil <br /> contamination at the 819 Hunter site has not impacted the groundwater beneath that site, <br /> no groundwater analytical data exists as yet to prove this. <br />