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ENVIRONMENTAL HEALTH DEPARTMENT <br /> Pau ` " SAN JOAQUIN COUNTY <br /> 2: y Donna K. Heron, R.E.H.S. Unit Supervisors <br /> y � Director 304 East Weber Avenue, Third Floor Cad Borgman, R E x s <br /> Laurie A. Cotulla, R.E.H.S, Stockton, California 95202-2708 Mike Huggins , R.E.H.S . , R D.I. <br /> � . , _�_- e • Progrmn Manager Douglas W. Wilson , R.E. H .S. <br /> 9C� FOR�` Telephone : (209) 468-3420 Margaret Lagorin, R .E.H.S . <br /> Fax : (209) 464-0138 Robert McClellon , R.E.H.S . <br /> Website: wwwsjgov.oi-g/ehd/ Jeff Carruesco, R.E.H.S . <br /> JAN 2 3 206 <br /> ROGER HUCKINS FERNANDO HATCHER <br /> 3436 ADMIRAL DRIVE 1201 S CENTER ST <br /> STOCKTON CA 95209 STOCKTON CA 95206 p `1 <br /> RE : Fernando' s Place Site Code : 505309 <br /> 1201 S . Center St. (APN : 14716003) ROM 0233 <br /> Stockton , CA 95206 SWRCB-CUF#: 012186 <br /> San Joaquin County Environmental Health Department (EHD) has reviewed <br /> Additional Subsurface Investigation and Interim Remediation Work Plan (Plan) <br /> submitted by your consultant, Advanced GeoEnviron mental (AGE) on December <br /> 28 , 2005 and has the following comments . <br /> In correspondence dated July 21 , 20057 EHD directed you to submit a work plan <br /> to continue the site assessment (plume definition) by September 1 , 2005 . EHD <br /> had concurred with AGE's conclusion that the petroleum hydrocarbon impacted <br /> ground water was not laterally or vertically defined and required additional <br /> investigation . <br /> The Plan submitted proposes installing three offsite continuous multi-channel <br /> tubing (CMT) polyethylene cased monitoring wells to a total depth of 198 feet <br /> below ground surface (' bgs). These CMT wells will be constructed with five (5) <br /> screened sections for sampling the ground water from previously identified <br /> hydrological units (HU ). <br /> Additionally, the Plan proposes installation of two 4-inch PVC-cased extraction <br /> wells onsite, one at each of the two former UST locations for ground water <br /> extraction (GWE ) . Pump tests on these extraction wells to evaluate the <br /> feasibility of using GWE to control the plume migration offsite and reduce the <br /> dissolved petroleum plume concentrations were also proposed in the Plan . <br /> Although EHD appreciates your intention to start cleaning up your site , EHD is <br /> concerned that your proposal to conduct an offsite vertical extent investigation of <br /> the dissolved petroleum plume before the onsite vertical extent of the plume has <br /> been delineated may not be the most cost-effective way to proceed . By placing <br /> CMT wells offsite that do not include potentially impacted HUs at depths greater <br /> than the currently known depths of the onsite plume , EHD feels that this offsite <br /> vertical investigation may not be adequate for addressing the vertical <br /> investigative requirement. Once the vertical extent of the petroleum plume has <br /> been defined onsite , the lateral extent of the impacted HU at all depths of <br /> concern could be more cost-effectively investigated and the use of the CMT <br /> wells can be optimized by including deeper HUs , if applicable . <br />