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*491MINT <br /> ENVIRONMENTAL HEALTH <br /> PpUIN SAN JOAQUIN COUNTY <br /> Unit Supervisors <br /> i Y mob" T Donna K.Heran,RE.H.S. Carl Borgman,R.E.H.S. <br /> a: A 304 East Weber Avenue, Third Floor Mike Huggins,R.E.H.S.,R.D.I. <br /> m: a Director <br /> Al Olsen,R.E.H.S. Stockton, California 95202-2708 Douglas W.Wilson,R.E.H.S. <br /> • <br /> Program g Manager s Telephone: (209) 468-3420 Margaret Lagorio,R.E.H.S. <br /> /FOR Laurie oA.g Cotulla, <br /> Man R.E.H.S. pax: (209) 464-0138 Robert McClellan,R.E.H.S. <br /> . <br /> Program Manager - Mark Barcellos,R.E.H.S. <br /> JUN 112002 <br /> GENE GABBARD JIM & 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 /> "Revised Work Plan for Additional Groundwater Monitoring Well Installation" dated May <br /> 24, 2002 that was submitted on your behalf by Ground Zero Analysis, Inc. and has the <br /> following comments. Please note that the work plan was submitted over two weeks late. <br /> The work plan as submitted is not approved because it fails to adequately address the <br /> issue of vertical assessment of the contaminant plume. Vertical assessment of the <br /> adsorbed and dissolved plumes, and identification of potential migration pathways, is <br /> critical at this point to guide the lateral investigation for both hydrocarbons and chlorinated <br /> hydrocarbons. SJC/EHD notes that MW-3 bottoms in a sand that is at least 7 feet thick, <br /> (per SB-3 log), that was not encountered in the down-gradient well MW-1, and that an <br /> apparently thin sand interval was encountered at approximately 30 feet below surface <br /> grade (bsg) in the cross-gradient and up-gradient wells MW-2 and MW-4. The thickness <br /> of the sand in MW-2 and MW-4, and the continuity of this sand to that in MW-3 is not <br /> known, but the sand may be a significant migration pathway and should be more fully <br /> characterized, as should the unit immediately underlying the sand. <br /> Per the California Code of Regulations (CCR), Title 23, Chapter 16, Article 11, Section <br /> 2725, all responsible parties for contaminated underground storage tank sites must <br /> conduct an investigation to determine the vertical and lateral extent of the unauthorized <br /> release that occurred at their site. In correspondences dated December 31, 2001 and <br /> March 13, 2002 you were directed by SJC/EHD to submit a work plan to fulfill this <br /> requirement. Two work plans have been submitted; both have failed to address this <br /> issue. This means that you are currently out of compliance with regulatory directives, and <br /> therefore your eligibility to the State Water Board Cleanup Fund may be in jeopardy. <br /> SJC/EHD again directs that a work plan be submitted to define the vertical extent of the <br /> contaminant plume. SJC/EHD strongly recommends that all limited access drilling <br /> technologies currently in industry practice be evaluated for use at this site. The work plan <br /> is due July 8, 2002, an extension will not be granted. <br /> The CCR also requires responsible parties to conduct feasibility testing to evaluate <br /> alternatives for remedying or mitigating the adverse effects of unauthorized releases. The <br /> alternatives must be evaluated for cost effectiveness. The current work plan proposes to <br /> perform a limited pumping test on MW-3, the well that has free product motor oil in it, to <br />