SITE INFORMATION AND CORRESPONDENCE

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SITE INSPECTION MEMORANL 2 3/30/99 CITY OF STOCKTON'S WESTSIDE SEWER INTERCEPTOR PROJECT NCTS,STOCKTON Only one worker had on an orange vest. All workers, except machine operators, wore hard hats. There was greater than 50 linear feet of open trench (unshored), where piping had been covered with sand. _. The trench was approximately 13 feet deep and six (6) feet wide. Another piece of construction equipment was pushing stockpiled dirt back into the trench behind excavation activities. We observed that the workers inside the trench were barehanded and were smoking cigarettes while in the trench. I gave my business card to the man in the orange vested workman (KENKO) and told him we were there to observe trenching and soil sampling activities. Later a woman arrived, who stated she represented Sverdrup. I also told the Sverdrup representative that I was there to observe trenching activities and specifically soil sampling techniques. She stated that the Precision Enviro-Tech technician was sampling every 50 feet and was also sampling at another location off-site Rough-n-Ready Island. Based on the rate of progress made during trenching activities at this inspection, it seemed improbable that one person could adequately sample two locations in this manner. The Precision Enviro-Tech technician arrived on the scene to take soil samples of the trench. Precision Enviro-Tech is the laboratory contractor under Sverdrup, the environmental management company under the City of Stockton. I introduced myself and stated that I was there to observe sampling techniques. The technician put on protective gloves and took a clear glass jar from his truck. He walked over to the trench and asked a KENKO worker to give him a piece of soil from the sidewall of the trench. No visual or sensory inspections were followed by the technician. A worker in the trench, who was previously smoking a cigarette, barehandedly grabbed a fist full of soil from the sidewall and threw it up to the technician. The clod of black clay material fell to the ground where it collected loose dirt from the asphalt pavement. The technician picked up the clod, wiped off the dirt, and put a piece of the clod into the glass jar(see photo#6 upper right corner). From my observations, the technician did not survey the depth of where the sample was taken nor the location along the linear trench. There were no painted/chalked markings on the pavement to physically identify the sampling location. This was the only sampling that occurred during the period of my inspection. Furthermore, no one was screening with a Flame Ionization Detector (FID) for Health and Safety purposes as described in the Clayton Plan. I was not approached or introduced to a Health and Safety Officer or a Sverdrup Quality Assurance Officer during the course of the inspection. CONCLUSIONS According to the Clayton Plan, these sampling techniques do not represent approved procedures. Sverdrup representatives and Navy personnel have stated that all samples, soil and water, have been found uncontaminated since sampling began on the island. Based on my observations of soil sampling, I question the viability of analytical results from soil samples taken at NCTS, Stockton. I also question Health and Safety procedures associated with construction activities. The purpose of sampling and analyzing soil and water along this easement is to provide Health and Safety to workers and to ensure that construction activities do not impact known or unknown contamination (i_e., groundwater plumes). Secondarily, it was anticipated that analytical results of soil and groundwater quality would be used by the Navy to determine whether there were any releases to the