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SERVICES q�lN <br /> s PUBLIC FftALTH oA. •...� <br /> SAN JOAQUIN COUNTY <br /> ENVIRONMENTAL HEALTH DIVISION <br /> M. D. M.P.H. Actin Health Officer <br /> Ernest M. Fujimoto, $ <br /> 304 E. Weber Ave., Third Floor • P. O. Box 388 • Stockton, CA 95201-0388 <br /> 2091468-3420 <br /> LLOYD GUMS APR 031996 <br /> 731 BIRCHWOOD DRIVE <br /> LODI CA <br /> RE: SITE CHARACTERIZATION REPORT REVIEW SITE CODE: 1319 <br /> 303 S. CHEROKEE LANE.LODI <br /> San Joaquin County Public Health Services Environmental Health Division(PHS/EHD) Site Mitigation staff have <br /> recently reviewed the Site Characterization Report prepared by Tag Laboratories, Inc. (TLI) for the above <br /> referenced site and are providing the following comments. <br /> On December 5, 6,and 7, 1995 TLI mobilized a drilling crew to the above referenced location for the purpose of <br /> site characterization. The drilling operations were conducted with oversight from PHS/EHD Site Mitigation. On <br /> several occasions PHS/EHD representative Ronald Rowe made observations of TLI staff activities including <br /> practices which required inquiry. <br /> These practices included the inappropriate use of soil sample screening bags which were unacceptable due to the <br /> production of volatile gases which interfered with field photoionozation detection (PID) equipment employed to <br /> estimate potential soil contamination. It was noted that bags which held soil samples from borings B-1, 2, and 8 <br /> generated PID values of 24 to 78 PPM although little or no staining or olfactory odor was detectable by PHS/EHD, <br /> TLI field geologist or drillers. As recommended by PHS/EHD an empty bag was then checked by the TLI field <br /> geologist producing a background PID value of 41 PPM. The PHS/EHD representative suggested an alternative <br /> sampling method after discovering this error. Since accurate and representative PID sing is critical to <br /> determining which samples are to be submitted for laboratory analysis, PHS/EHD is concerned with what may <br /> have been overlooked as a result of sample screening practices performed by TLI staff. <br /> Only two of the actual and unrepresentative field screening PID readings appear on boring log B-8 in the first and <br /> second intervals (42.7 and 31.1 PPM) sampled. Similar errors were made on Borings B-1 and B-2 as well. In <br /> addition, during boring of B-1, PHS/EHD staff noted a diesel odor at approximately 35 feet below surface grade <br /> (BSG) and suggested the boring be advanced an additional 5 feet or to clean soil for the purpose of obtaining <br /> lateral and vertical definition potentially avoiding remobdization. This recommendation was ignored by the TLI <br /> field geologist. <br /> TLI staff then began completing Hand Anger(HA)borings 7, 8 and 10. TLI staff completed HA 10 by hand and <br /> HA 7, and 8 by drill rig. In each boring HA 7, 8 and 10 all site workers from TLI and PHS/EHD observed what <br /> appeared to be nonnative soil at 0 to 5 feet BSG. In each instance PHS/EHD suggested that each boring be <br /> advanced an additional 5 feet or to clean soil for the purpose of obtaining both lateral and vertical definition again <br /> avoiding remobilization,this recommendation was also ignored by the TLI field geologist. <br /> At this time PHS/EHD representatives contacted Ken Jones of TLI directly by cellular telephone from TLI's drill <br /> rig to report the observations and recommendations encountered with no commitment from TLI . At that time, <br /> PHS/EHD staff contacted the Supervisor of the PHS/EHD Site Mitigation Unit to discuss the situation. At that <br /> time PHS/EHD Site Mitigation Unit Supervisor Diane Hinson recommended that TLI field staff approach TLI <br /> management and the Responsible Parties(RP)and if no commitment was made to correct their app <br /> mal <br /> evaluation of the report would follow. TLI drillers and geologists commented that they were far behind schedule <br /> and management at TLI had instructed them to disregard PHS/EHD recommendations due to"time and budgeting <br /> constraints". PHS/EHD again recommended that the TLI field geologist contact his supervisor and RP to inform <br /> them of the conditions observed and to consider the cost of remobilization and laboratory analysis to their client <br /> A Division of San Joaquin County Health Care Services <br />