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a <br />Fernando's Place <br />1201 S. Center St. <br />Stockton, CA 95206 <br />You and your consultant should discuss these reductions and <br />reduction in sampling wells and chemical analysis should be <br />days of the date of this letter. <br />February 24, 2009 <br />Page 2 <br />others and a specific proposal for <br />submitted to the EHD within 30 <br />In correspondence dated July 21, 2005, the EHD concurred with your consultant's conclusion <br />that the dissolved petroleum ground water plume was not vertically or laterally defined and in <br />correspondence dated October 19, 2006, the EHD provided the following concerns they had <br />with the site data: <br />1. A lack of vertical ground water plume delineation near MW -4 and MW -5; <br />2. A lack of lateral ground water plume delineation in all five hydrological units (HU), <br />particularly toward the north and the east and toward the residential areas; <br />3. A lack of monitoring wells with screened intervals between 40 feet below ground surface <br />(' bgs) and 100' bgs; <br />4. The potential for vapor intrusion to the nearby residences located around the site has <br />not been evaluated. Some of those houses appear to have either half or full basements <br />and are very close to monitoring wells with elevated levels of dissolved petroleum in the <br />ground water; <br />5. The lack of sorbed and dissolved contaminant mass estimates for the site, and <br />6. The apparent instability of the dissolved plume. <br />In the October 2006 correspondence the EHD also requested the submittal of cross sections <br />that show ALL of the wells and screen intervals, with the lithological units identified in the boring <br />logs correlated. The EHD is concerned that the monitoring of sand units that may serve as <br />contaminant migration pathways has not been demonstrated. <br />In addition, the EHD has some concerns with groundwater data from CMT well casings <br />(currently installed at your site) at other sites and a satisfactory method of destroying these <br />wells has not been found, so installation of single cased wells in the lithological units identified <br />must be performed on future well installations. <br />The above <br />items must <br />be addressed and a work plan should be <br />submitted <br />to the EHD within <br />45 days of <br />the date of <br />this letter that proposes the installation of <br />additional <br />monitoring wells. <br />The soil vapor extraction/ground water extraction unit has still not been fully constructed (no <br />electrical hookup) and a completion date has not been provided. The groundwater plume from <br />your site is large, undefined and unstable and has high contaminant concentrations, so interim <br />remediation is a necessity. The EHD directs you to complete the remedial unit installation and <br />place the system online as soon as other agency approvals are given. <br />You may direct your submittals and any questions <br />468-34549. -o <br />you may have to Michael Infurna, at (209) <br />Michael J. Infurna Jr., REHS <br />Senior Registered Environmental Health Specialist <br />Margar�o, RENS <br />Program Coordinator <br />ca James Barton, CVRWQCB <br />Mark Owens, SWRCB CUF— <br />William Little, Advanced GeoEnvironmemal, Inc., 837 Shaw Rd., Stockton, CA 95215 <br />