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ENVIRONMENTAL HEALTH DEPARTMENT <br /> Pp U. IN SAN JOAQUIN COUNTY <br /> Donna K. Horan, R.E.H.S. (Iaait Supervisors <br /> 304 East Weber Avenue, Third Floor <br /> Director Carl Borgman, R.E.H.S . <br /> Laurie A. Cotulla, R.E.H.S, Stockton, California 95202-2708 Mike Huggins, R.E.H.S. , R.D. I. <br /> • Mana er <br /> Pro ram <br /> s x Telephone : (209) 468-3420 Douglas W. Wilson, R.E.H.S . <br /> a F o'R Margaret Lagorio, R.E.H. S . <br /> Fax : (209) 464-0138 Robert McClellon, R .E.H. S . <br /> Website: www.sjgov.org/ehd/ Jeff Carruesco, R.E. H.S . <br /> VELMA MASTERSON MAY 2 2 2006 <br /> BENETO INC <br /> PO BOX 980220 <br /> WEST SACRAMENTO CA 95798 <br /> RE : DARPETRO, INC Site Code: 1060 <br /> 749 E CHARTER WAY <br /> STOCKTON, CA 95202 <br /> I <br /> San Joaquin County Environmental Health Department (EHD) has received and <br /> reviewed Re: 21,d Addendum of Monitoring Wells (MW- 17 & MW- 18) dated March 21, <br /> 2006 and SVE Work Plan dated March 28, 2006 (Second Addendum) dated 18 April <br /> 2006 , prepared and submitted by California Geophysical Group (CGG ) on your behalf. <br /> The work plan for soil vapor extraction testing with addendums is approved . <br /> EHD still cannot approve the work plan for installation of monitoring wells MW- 17 and <br /> MW- 18 . The proposed construction of both wells now has a 5-foot gap between the <br /> screen sections at the base of the borings and the blank casing extending up to the <br /> surface. EHD presumes the gap would be made up with additional blank casing and <br /> may have approved the construction with a conditional approval , but after discussing <br /> the well construction details , the work plan proposes or suggests construction of the <br /> wells utilizing mud rotary drilling and installation of a conductor casing . <br /> EHD can see why a conductor casing could be justified for the area the wells are to be <br /> located in to minimize cross contamination , but such a well requires a different well <br /> construction from that proposed . The proposed construction gives no details for boring <br /> size, conductor casing size and depth , or any of the other details necessary to build <br /> such a well . The California Well Regulations require a minimum 2-inch annular space <br /> for grouting around each casing ; the originally proposed boring is not adequate to install <br /> both a conductor casing and the final well casing . EHD is confused on what is intended , <br /> so the work plan and addendums for the additional monitoring wells are not approved . <br /> Please submit to EHD by 05 July 2006 a new work plan for installing the deep <br /> monitoring wells or an addendum to the current work plan and addendums that clearly <br /> state the proposed well construction and drilling methods . As noted in the EHD letter of <br /> 08 February 2006 , "inadequate reports and/or work plans retard progress toward <br /> closure for your site . " We now await the third addendum . Please note that had the <br /> original work plan dated 24 January 2006 been clear, consistent and justified by the site <br />