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Chevron#9-6171 2 22 February 2005 <br /> 6633 Pacific Ave., Stockton <br /> 2. The Report's unnumbered table, titled Groundwater Monitoring Data and Analytical Results, shows <br /> that 4 of the 6 "dry"monitoring wells that were not sampled this quarter, have reported insufficient <br /> water for multiple quarters (Figure 2). It appears that your samplers, Gettler-Ryan, do not sample if <br /> the wells contain less than a foot and a half of measurable water. <br /> Monitoring Well MW-8 MW-9 MW-10 MW-12 MW-13 MW-14 <br /> (depth) (39.02' 38.99' (38.65' 39.75 38.63' 38.41' <br /> Consecutive Quarters <br /> not sampled 4 5 4 2 1 1 <br /> MW-8, -9, and—10 are onsite wells. MW-12, -13 and—14 are downgradient wells across Pacific <br /> Avenue. I request that Secor conduct an evaluation to determine whether the'dry wells" should be <br /> replaced, include those recommendations in the next quarterly monitoring report, and provide a <br /> Work Plan with current well construction details and a schedule for the work if replacement wells are <br /> needed. <br /> 3. It appears from the data table that several petroleum hydrocarbon constituents, which were previously <br /> tested, have been removed from the monitoring program after several quarters of non-detect results. <br /> The analytical method detection limits (MDLs) reported for those constituents, 2 µg/L, is too high for <br /> comparison to water quality objectives. Fuel oxygenates, including MtBE, and fuel additives ethylene <br /> dibromide (EDB) and 1,2-Dichloroethane (1,2-DCA) should be reported at MDLs of 0.5 µg/L. <br /> Therefore, during the next quarterly monitoring event, you will also test all wells for fuel oxygenates, <br /> EDB and 1,2-DCA; and report them at the MDLs of 0.5 µg/L. If detection of any constituent results <br /> from the lower MDLs, then analyses for those constituents will resume quarterly for those wells. <br /> 4. As stated above, the field technician noted a problem with sampling access for MW-4 in Gettler- <br /> Ryan's Well Monitoring/Sampling Field Data Sheet, which says "Inaccessible— buried under <br /> landscaping". As a result, MW-4 was not sampled for the first time during this quarter. Please work <br /> with the Chevron station to uncover MW-4 and determine whether it is damaged. If MW-4 has been <br /> damaged, then destroy it under permit from San Joaquin County Environmental Health Department, <br /> in accordance with their ordinance. If damaged include a Work Plan for replacement of MW-4 with <br /> the next quarterly report. <br /> 5. All future reports and workplans are to follow the Tri-Regional Recommendations for Preliminary <br /> Investigation and Evaluation of Underground Storage Tank Sites and Appendix A (Tri-Regionals). <br /> Please refer to the Internet link under the header of this letter to download the Tri-Regionals. The <br /> Tri-Regionals call for quarterly reports that include isoconcentration maps of each contaminant, as is <br /> relevant to the lateral extent of contamination, and geologic cross sections showing the vertical extent <br /> of contamination. <br /> 6. All subsequent quarterly reports must include the well screen intervals for each monitoring well in the <br /> data table. <br />