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ENVIRONMENTAL HEALTH DEPARTMENT <br /> Pp U,INSAN JOAQUIN COUNTY <br /> .cl Unit Supervisors <br /> Donna K.Heran,R.E.H.S. Carl Borgman,R.E.H.S. <br /> uQi j < Director 304 East Weber Avenue, Third Floor Mike Huggins,R.E.H.S.,R.D.I. <br /> Al Olsen,R.E.H.S. Stockton, California 95202-2708 Douglas W.Wilson,R.E.H.S. <br /> • '�., ��,..P. Program Manager Telephone: (209) 468-3420 Margaret Lagorio,R.E.H.S. <br /> 9Ci s oa�� Laurie A.Cotulla,R.E.H.S. Robert McClellon,R.E.H.S. <br /> Program Manager Fax: (209) 464-0138 JAN 2 3MtWellos,R.E.H.S. <br /> GENE GABBARD JIM k SHEYLA CREEL <br /> po BOX 1260 12511 MUNDY <br /> STOCKTON CA 95212 LODI CA 95240 <br /> RE: Gene Gabbard, Inc. SITE CODE: 1090 <br /> 640 N. EI Dorado Street <br /> Stockton CA 95202 <br /> San Joaquin County Environmental Health Department (SJC/EHD) has reviewed the <br /> "Work Plan for Well Installation and Feasibility Study, Second Revision" dated <br /> September 6, 2002 that was submitted by Ground Zero Analysis, Inc. (Ground Zero) and <br /> has the following comments. <br /> In correspondence dated April 16, 2002, you were informed that the proposed <br /> installation of three additional monitoring wells for investigation of the lateral extent of the <br /> shallow contaminant plume was approved by SJC/EHD. The deadline for the installation <br /> of these wells was June 14, 2002. This site is currently out of compliance with <br /> regulatory directives for having failed to install these wells. In correspondence dated <br /> June 11, 2002 you were informed that SJC/EHD did not approve the reduction of well <br /> installations from three to two, and you were once again directed to submit a work plan <br /> to complete the investigation of the vertical and lateral extent of the contamination at <br /> your site. The deadline for the submittal of the work plan was July 8, 2002. In the <br /> current work plan revision Ground Zero has again proposed only two wells. Two wells <br /> are not adequate to delineate the volatile organic chloride (VOC) plume at this site and <br /> this change is not approved by SJC/EHD. Technical considerations indicate that three <br /> additional monitoring wells are the minimum number of monitoring wells required for <br /> lateral plume delineation. Ground Zero's assertion that they were denied an <br /> encroachment permit from the City of Stockton (City) could not be substantiated; the City <br /> has informed SJC/EHD that while monitoring wells will not be allowed to be installed in <br /> traffic lanes, their installation would be allowed in parking lanes and sidewalks, both of <br /> which are present at this intersection. <br /> The submitted work plan still does not provide for vertical assessment of the <br /> groundwater contamination. In the previously disapproved `Revised Work Plan for <br /> Additional Groundwater Monitoring Well Installation" dated May 24, 2002, Ground Zero <br /> stated that the reason they did not address the issues of vertical definition in <br /> groundwater was because of limited accessibility at the site. They knew of no drill rig <br /> that could work inside the building and reach the total depth needed. SJC/EHD directed <br /> an evaluation of all limited access drilling methods currently in industry practice. In the <br /> current work plan, Ground Zero now proposes to not complete the vertical assessment <br /> at this site out of concern that drilling through the contaminated source area would <br /> create a conduit for the contamination to travel deeper into the aquifer. In lieu of <br />