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PUBLIC HEALTH SERVICES <br /> SAN JOAQUIN COUNTY <br /> ENVIRONMENTAL HEALTH DIVISION <br /> Karen Furst, M.D., M.P.H., Health Officer <br /> 304 East Weber Avenue, Third Floor • Stockton, CA 95202 4`ikio.f� <br /> 2091468-3420 MAY 2 12001 <br /> CARL NAVARRA <br /> 485 BLEWETT ROAD <br /> TRACY CA 95376 <br /> RE: 7500W. 11th Street SITE CODE: 1392 <br /> Tracy CA 95376 <br /> San Joaquin County Public Health Services, Environmental Health Division (PHSIEHD) has <br /> reviewed the Groundwater-Qualify Monitoring Report dated February 2001 that was prepared <br /> by The San Joaquin Company Inc. (SJC) on your behalf and has the following comments. <br /> The report documents the groundwater monitoring and sampling event that took place at the <br /> above referenced site on November 28, 2000. The report again brought up the issue of <br /> collecting stabilization parameters during the purging of the monitoring wells prior to sampling. <br /> PHSIEHD has previously informed you that we will not recognize groundwater samples <br /> collected without measuring stabilization parameters (PHSIEHD correspondence dated <br /> September 19, 2000). Collecting stabilization parameters, as previously stated, is <br /> recommended by both the California State Water Resources Control Board, as referenced in <br /> the Leaking Underground Fuel Tank Field Manuel, and the United States Environmental <br /> Protection Agency. Therefore, PHSIEHD maintains our position that stabilization parameters <br /> are required prior to collecting groundwater samples for laboratory analysis. <br /> In their discussion of monitoring well purging, SJC states that measurement of parameters while <br /> purging unnecessarily adds to the complexity and cost of the groundwater sampling operations. <br /> This is a specious statement. Measuring parameters while purging is considered to be standard <br /> industry practice; it is observed on an extremely routine basis and does not appear to be <br /> complex in any way. In addition, the request to purge a standard fifteen gallons of water from <br /> each well would likely produce a greater volume of purge water that will need to be disposed of <br /> than would purging three to five well volumes. <br /> As the responsible party you were informed by PHSIEHD in the September 19, 2000 <br /> correspondence that quarterly groundwater monitoring at this site is to continue until directed <br /> otherwise by PHSIEHD. The third round of groundwater monitoring was to;have occurred in <br /> February 2001. If it has not taken place, please schedule it immediately. <br /> Donna Heran, RENS, Director <br /> Environmental Health Division <br /> Lori Duncan, Senior REHS Dot Lofstrom R.G. <br /> LOP/Site Mitigation Unit IV Engineering Geologist <br /> cc: Marty Hartzell, CVRWQCB <br /> Dai Watkins, SJC <br /> A Division of San Joaquin County Health Care Services <br />