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Thrifty Oil Company <br /> 1250 N. Wilson Way <br /> Page 3 of 3 <br /> The gradient has a profound effect on capture zone geometry and must be taken into <br /> account to properly design a groundwater extraction system. EHD disagrees with <br /> TOC's contention that the most recent gradient data should be used to calculate the <br /> `stagnation point' as the gradient data presented by TOC has been highly variable over <br /> time and as any remediation system must be designed to be effective under variable <br /> gradient and groundwater flow directions. EHD notes after a partial review of reports <br /> that TOC has reported gradients on the site as high as 0.89. EHD has not verified or <br /> recalculated any gradient data presented by TOC. <br /> As to the work plan itself, <br /> The work plan is adequate and necessary [H&S 25299.37, subd(c)(3)] and is <br /> approved with the above noted conditions and work plan comments properly <br /> addressed. <br /> Please submit a Well Permit Application Form and $89 per parcel prior to scheduling a <br /> drilling date for the CPT work. For work done in the city right of way, EHD will require a <br /> copy of the City of Stockton encroachment permit(s) prior to issuing our permit(s). You <br /> should contact George Montrose at the city's "Permit Center" at (209) 937-8633 for <br /> encroachment permit requirements. EHD advises that the process to obtain a city <br /> permit can take a considerable amount of time with numerous submittals potentially <br /> required. EHD strongly recommends that TOC start the process immediately. <br /> Thank you for your cooperation in monitoring and evaluating your remedial efforts at this <br /> site. Please continue to address your submittals to Michael Infurna and you may either <br /> phone him at (209) 468-3454, or contact him by electronic mail at <br /> minfurna@sjcehd.com. <br /> Donna Heran, RENS, Director <br /> Environmental Health Divisi n <br /> Michael J. Infurna Jr., Senior RENS Nuel C. Henderson Jr. RG <br /> LOP 1 Site Mitigation Unit IV LOP 1 Site Mitigation Unit IV <br /> MI/ <br /> c: CVRWQCB —James L.L. Barton, Sacramento. <br /> c: SWRCB-CUF — Marc Owens, Sacramento. <br />