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ENVIRONMENTAL HEALTH DEPARTMENT <br /> SAN JOAQUIN COUNTY <br /> •• —s��'.pG Unit Supervisors <br /> Donna K.Heran,R.E.H.S. <br /> 304 East Weber Avene, Third Floor <br /> Director uCarl Borgman,R.E.H.S. <br /> Mike Huggins,R.E.H.S.,R.D.I. <br /> AI Olsen,R.E.H.S. Stockton, California 95202-2708 Douglas W.Wilson,R.E.H.S. <br /> • c4�iFo'a�'P • Program Manager Telephone: (209) 468-3420 Margaret Lagorio,R.E.H.S. <br /> Laurie A.Cotulla,R.E.H.S. Fax: (209) 464-0138 Robert McClellon,R.E.H.S. <br /> Program Manager Mark Barcellos,R.E.H.S. <br /> AMERCO REAL ESTATE CO JUN 1 12004 <br /> REID RINER <br /> 2721 N CENTRAL AVE STE 700 <br /> PHOENIX AZ 85004 <br /> RE: U-Haul #709-50 Site Code: 1772 <br /> 2701 N. Wilson Way RO#: 00574 <br /> Stockton, CA., 95215 <br /> San Joaquin County Environmental Health Department (EHD) has reviewed <br /> Work Plan for Additional Assessment of Hydrocarbons In Soil and Ground Water <br /> dated May 13, 2004 as submitted by Blaes Environmental Management Inc. <br /> California Health and Safety Code Section 25296.10(c)(3) requires that EHD <br /> indicate elements of the work plan that are adequate and necessary, therefore <br /> EHD provides the following comments on the work plan. <br /> The work plan proposes to install two onsite borings (CPT-1 and CPT-2) to 150 <br /> feet below ground surface (bgs). It also proposes installation of two offsite <br /> borings. Each boring is to have two "nested" two-inch PVC casings installed. <br /> They are to be referred to as monitoring wells MW-13 and MW-14 "A" and "D" <br /> cased wells. Selected soil samples will be analyzed for TPHg, BTEX, and "full <br /> list" EPA Method 8260 (to include MtBE, 1 ,2-DCA, 1 ,1-DCA, TBA, TAME, DIPE, <br /> EtBE). The new wells are to be included in quarterly monitoring and reporting <br /> along with the other monitoring wells. <br /> EHD approves the CPT borings as adequate and necessary work to be <br /> performed. EHD has concerns about the placement and construction of MW 13 <br /> and MW14. <br /> The proposed construction for MW-13 "A" and "D" is a well casing with a shallow <br /> screen interval of 40 to 65 feet bgs and a well casing with a deeper screen <br /> interval of 130 to 150 feet bgs. The proposed area to place MW-13 (northwest <br /> of MW-8A and MW-8C) should be investigated to define the groundwater <br /> contamination found in MW-8C that is screened from 60 to 85 feet bgs. MW-8A <br /> that is screened from 37 to 62 feet bgs, has been non-detect for 1 ,2-DCA and <br /> petroleum and defines the lateral extent of the ground water plume in the <br /> north/northwest quadrant at that interval. Placing a screened interval that <br /> crosses the "A" and "B" intervals is unnecessary and not approved by EHD. <br />