Laserfiche WebLink
3. EHD does not accept languages such as "current uses and importance of <br /> urgency of restoration must be considered on an economic basis" (Section 5.3), <br /> and"Common agreement of goals and methodology between the CVRWQCB, <br /> PHD/EHD,and the Owner is necessary before further outlaying capital" <br /> (Section 5.4). Such languages are irrelevant and do not belong in a work plan. <br /> EHD is the lead agency for this site and does not require CVRWQCB for a work <br /> plan approval or to issue directives. You are required by California Underground <br /> Storage Tank Regulations Title 23 to investigate and remediate underground tank <br /> related contaminations. Although economics are a factor,investigation and <br /> remediation work of contamination is not economic based,but groundwater- <br /> protection based. Please refrain from inserting such irrelevant languages in a <br /> work plan in the future. <br /> 4. Section C-2 proposes rinsing sample caps,bottles,and septa at various controlled <br /> parameters before using them for volatile and semi-volatile collection. EHD <br /> requests you not decontaminate your own bottles,but use lab-prepared volatile <br /> organic analysis (VOA) bottles. <br /> 5. Section C-2 proposes using bladder pump for collection of groundwater samples. <br /> EHD requests that you do not use a bladder pump. Bladder pumps can <br /> introduce potential cross-contamination,and has no control over volatility of the <br /> samples. Absolute control must be maintained to minimalize the loss of volatiles <br /> in the samples. EHD suggests you use deposable bailers for the collection of <br /> groundwater samples. <br /> 6. Section C-9 states that holding time of samples should not exceed 14 days from <br /> the time of collection. EHD reminds you that it is correct only if preservatives <br /> were used in the groundwater samples. If preservatives were not used, then the <br /> holding time is only 7 days. <br /> REASONS FOR DISAPPROVAL OF THE WORKPLAN (H&S 25299.37, subd.(C)(3 . <br /> Jeffrey Wong, Senior REHS -� , ZOdZ Nuel C. Henderson,Jr.,RG <br /> LOP/Site Mitigation Unit IV LOP/Site Mitigation Unit IV <br /> Cc: San Joaquin County District Attorney's Office-David Irey <br /> Cc: CRWQCB, Central Valley Region-Marty Hartzell <br /> Cc: D.K. Barber P.E. &Associates—Daniel Barber <br />