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San Joaquin County <br /> onmental Health Department DIRECTOR <br /> Donna Heran,REHS <br /> 1868 East Hazelton Avenue <br /> PROGRAM COORDINATORS <br /> m: < Stockton, California 95205-6232 Robert McClellon,REHS <br /> Jeff Carruesco,REHS,RDI <br /> Kasey Foley,REHS <br /> cq�I F°R? P Website: www.Sjgov.org/ehd Linda Turkatte, REHS <br /> Phone: (209) 468-3420 Rodney Estrada,REHS <br /> Fax: (209) 464-0138 Adrienne Ellsaesser, REHS <br /> October 15, 2014 <br /> Carl Knowles, Successor Trustee <br /> Knowles Family Trust Agreement <br /> P.O. Box 640 <br /> Woodbridge, CA 95258 <br /> LOP Site: Knowles-Rook <br /> 102 South Wilson Way <br /> Stockton, CA 95205 <br /> Subject: Failure to Inform the Environmental Health Department of Changes to <br /> Groundwater Sampling and Proper Sampling Protocols <br /> The San Joaquin County Environmental Health Department (EHD) must address concerns with <br /> you regarding,scheduling of groundwater sampling events and proper sampling protocols that <br /> should be followed during monitoring events. To minimize differences in data derived from <br /> changes of consultants, field personnel, laboratories, etc., the EHD has issued groundwater <br /> sampling guidelines that reflect the guidelines published by the California State Water resources <br /> Control Board (SWRCB) in the Leaking Underground Fuel Tank Guidance Manual (LUFT <br /> Manual) issued in 2012, portions of which are attached for your reference. By minimizing <br /> variations in data obtained by different field personnel or consultants, the data obtained by one <br /> can be utilized by subsequent workers, thereby preserving the value of previously obtained <br /> data. <br /> The EHD plays a role in ensuring that reliable data is obtained from field work by observing the <br /> work in progress to verify proper equipment and procedures are utilized to obtain samples; the <br /> LUFT Manual referring to site assessment work, makes the following statement (page 15-6): <br /> "An inspector from the lead agency or local oversight agency which has issued a specific permit <br /> has the authority to be present during site work, unless prior approval to proceed without an <br /> inspector onsite has been obtained" and "The agency has the regulatory authority to reject <br /> analytical or field results obtained during field work if the proper inspection arrangements have <br /> not been made and there is a reasonable suspicion that the data are not valid."The EHD is of <br /> the opinion that the same principle holds for groundwater monitoring events, and the EHD is not <br /> aware of any oversight agency that does not require advance notice of groundwater monitoring <br /> events. There have been several recent instances of failures to inform the EHD of changes in <br /> scheduled monitoring events that have deprived the EHD of the opportunity to observe the <br /> monitoring and sampling processes at your Local Oversight Program (LOP) site. Despite <br /> reminders that the EHD should be notified of such scheduling changes, failure to notify the EHD <br /> has been repeated, taking on the appearance of evasiveness, which has the EHD concerned. <br /> EHD was informed that a groundwater sampling event was to take place on December 23, 2013 <br /> at your LOP site, but no one was present to perform the work at the appointed time when the <br />