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y FILL <br /> ENVIRONMENTAL HEALTH DEPART <br /> Po'UIN SAN JOAQUIN COUNTY ' <br /> Unit Supervisors <br /> Donna K.Heron,R.E.H.S. 304 East Weber Avenue, Third Floor Carl Borgman,R.E.H.S. <br /> Q: < <br /> .A Director Mike Huggins,R.E.H.S,R.D.I. <br /> Al Olsen,R.E.H.S. Stockton, California 95202-2708 Douglas W.Wilson,R.E.H.S. <br /> • �:, p. Program Manager Telephone: (209)468-3420 Margaret Lagorio,R.E.H.S. <br /> 9Cj g 6-, a Laurie A.Cotulla,R.E.H.S. Robert McClellon,R.E.H.S. <br /> Program Manager Fax: (209) 464-0138 Mark Barcellos,R.E.H.S. <br /> KEN GILLIES JUN 17 2004 <br /> GILLIES TRUCKING <br /> P O BOX 8303 <br /> STOCKTON CA 95208 <br /> RE: Gillies Trucking SITE CODE: 1703 <br /> 3931 Newton Road RO: 0264 <br /> Stockton, CA 95205 <br /> San Joaquin County Environmental Health Department (EHD) has received and <br /> reviewed the Fourth Quarter 2003 Report (QR), dated 21 January 2004, <br /> prepared by your consultant Upgradient Environmental Consultants (UEC), and <br /> the 09 April 2004 letter from Member of Congress Richard W. Pombo with an <br /> enclosed copy of UEC's 24 March 2004 letter conveying a -request by Gillies <br /> Trucking for closure consideration for this site. The EHD had not received the 24 <br /> March 2004 letter previously and the Central Valley Regional Water Quality <br /> Control Board (CVRWQCB) does not have a copy of that letter. The EHD <br /> comments as follows: <br /> The geological model presented by UEC for the Modesto and upper two sand <br /> units of the Riverbank formations appears to be reasonable. Sufficient <br /> information has not been developed for UEC to characterize the possible third <br /> sand unit of the Riverbank formation. The hydrological conductivities presented <br /> indicate that the sand units are the more likely lateral migration pathways for <br /> impacted groundwater and the fine-grained units most likely impede migration of <br /> impacted groundwater. <br /> UEC shows, in Figure 8 of the QR, that impacted groundwater has been <br /> delineated in the First Riverbank channel sand, generally lying between 65 and <br /> 70 feet below surface grade (bsg). The EHD does not concur with that <br /> interpretation, as it appears that the main axis of that channel sand has not been <br /> characterized after comparing the data presented on Figures 8 and 9 of the QR. <br /> In addition, UEC discounts the analytical results for the groundwater sample <br /> collected at 65 feet bsg in CPT-1 as being too high; the EHD agrees that there <br /> may be a problem with the results for this sample, but even if greatly discounted, <br /> the results are consistent with the high contaminant concentrations detected in <br /> GT-4 and GT-8 at depths between 55 and 65 feet bsg. This data appears to <br />