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from this office. Selected soil samples shall include at a minimum the historic low and high groundwater <br /> elevation equivalent and the current capillary fringe. Traditional TPH as gasoline and diesel as well as <br /> BTEX analyses are also required. <br /> The FGL analytical data report submitted to this office confirms the presence of 1,2-Dichloropropane at 1.8 <br /> ug/L from the Public Water System Wellhead (PHS/EHD #WA460903) sampled July 15, 1997. 1,2- <br /> Dichloropropane is a Regulated Organic Chemical and is a known carcinogen. PHS/EHD strongly <br /> recommends that the responsible parties at this site carefully monitor this wellhead to protect consumers <br /> and or users of this water supply. On July 7, 1997 PHS/EHD staff requested, during a telephone <br /> conversation with Don Thompson and later with Frank and John Guinta, that the public water supply well <br /> construction details be provided immediately in order to assess potential public health risks associated with <br /> contaminants at this site. On July 9, 1997 PHS/EHD staff visited the site to record the approximate <br /> distance of the well in question to the known contaminant plume. Again Mr. Guinta was asked for <br /> constuction details in the presence of Mr. Thompson. During our July 9, 1997 meeting at the San Joaquin <br /> County District Attorneys offices PHS/EHD formally requested well construction details for this public <br /> water supply well. PHS/EHD now directs the responsible parties to immediately evaluate and report <br /> to PHS/EHD the construction details of this well to insure that this well does not act as a conduit for <br /> vertical contaminant transport. The responsible party shall at a minimum determine the total depth, <br /> screen interval,and type and depth of grout seal if any. In the event this information is not available in the <br /> form of boring logs and well drillers completion reports the well shall be evaluated by down hole video <br /> logging performed by a qualified contractor. In addition the workplan addendum must include <br /> investigative methodologies for chlorinated solvents particularly in the vicinity of the former waste oil <br /> tanks at this site. A full scan report utilizing EPA Method 8260 is mandatory on a quarterly basis until <br /> further written notice from this office. <br /> Conventional monitoring well networks proposed in the REE workplan for this Underground Fuel Tank <br /> (UST) leak site may be insufficient to properly locate and define the extent or existence of MTBE / Fuel <br /> Additive / Chlorinated Solvent plumes as evidenced by the vertical and horizontal variations of <br /> contamination observed at this site. MTBE plumes can be non-elliptical, long, narrow and erratic <br /> (meandering), chlorinated solvent plumes can be unlimited in depth and length. Therefore, PHS/EHD <br /> directs you to perform a detailed, expedited site assessment using depth discrete and continuous core <br /> sampling to define and quantify the full three-dimensional extent of MTBE and other additives,Total <br /> Petroleum Hydrocarbons, Benzene, Solvents and other known or suspected contaminants in <br /> groundwater. <br /> In addition, and as agreed to during our July 9, 1997 meeting at the District Attorneys Offices the <br /> responsible party(Frank Guinta)was to submit UST removal and replacement plans to PHS/EHD no later <br /> than August 1, 1997. The relevance of the tank system pull and replacement plan to the site assessment is <br /> in monitoring well placement. Since the responsible party has failed to meet the tank system closure and <br /> replacement submittal deadline to date, PHS/EHD cannot insure that monitoring wells placed at the site <br /> will not be destroyed,need to be replaced or duplicated as a result of future construction activities at the <br /> site. <br /> The REE workplan proposes several wells to be located a considerable distance to the North-West from the <br /> current known core contaminant sources. These wells shall be relocated and redistributed at the site. No <br /> less than seven boreholes completed as monitoring wells must be placed at the following positions with <br /> appropriate discrete screen intervals(each borehole may require more than one well completion); surround <br /> each of the current UST and dispenser island locations to further assess past, current or potential future <br /> releases recognizing the inconsistencies in past and current monitoring equipment performances and the <br /> known contaminant distribution. At least three of these boreholes shall be continuous cores. At least two <br /> separated dual completion (nested)wells shall be installed as sentry wells on the south side of the facility <br /> building to intercept contaminant migration toward the public water supply well. These boreholes shall <br /> also be employed to further define any potential chlorinated solvent plume which may have originated <br /> 2 <br /> I <br />