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v � <br /> kn KLEINFELDER <br /> comply with the South Manteca E1R. If the RWQCB or the DTSC has specific knowledge of the <br /> alleged application of the rinse water to the orchard area we respectfully request that they make <br /> that information available, from which we would comply with a revision to the sampling <br /> locations noted to include the orchard area. <br /> ITEM 2 <br /> Section 3.1.2 on Page 5 states that the locations of the upgradient and downgradient monitoring <br /> wells are shown on Plate 2. Plate 2 does not show the proposed well locations. A figure <br /> showing the proposed well locations need to be provided. <br /> As requested Plate 2 has been attached. Plate 2 shows the location of the proposed monitoring <br /> well locations. <br /> ITEM 3 <br /> Section 3.1.2 on Page 6 states that the two proposed monitoring wells will be surveyed to allow <br /> the assessment of groundwater gradients. Regional Board and DTSC staff do not concur that <br /> two monitoring wells are sufficient to determine the groundwater gradient. Additional <br /> information is needed regarding another well in the area with an appropriate screened interval <br /> to use for triangulation, or you need to install an additional monitoring well. <br /> As requested a third monitoring well location has been added to the proposed scope of work. <br /> ITEM 4 <br /> The Revised Work Plan proposes metal analyses, but does not specify which metals or analytical <br /> methods. This information must be provided. <br /> As requested the following laboratory method and list of metals is included. The proposed <br /> metals analyses will be performed by EPA Method 601013. The list is the CAM 17 metals. The <br /> laboratory list of metals to be included in the laboratory analysis is as follows: <br /> Antimony, arsenic, barium, beryllium, cadmium, chromium, cobalt, copper, lead, mercury, <br /> molybdenum, nickel, selenium, silver, titanium, vanadium, and zinc. <br /> ITEM 5 <br /> Due to the volatile chemical nature of many of the constituents of potential concern, soil gas <br /> samples are needed in the concrete washout pad and all former chemical storage areas. <br /> Soil gas samples at this point of the investigation appears to be more detailed than is warranted at <br /> this time. The investigation as proposed is designed to be of a probative scope of work to <br /> determine the presence/absence of contaminants on the site and assess their potential impact if <br /> present. We respectfully request to defer the task of collecting soil gas samples until after the <br /> 27125.WP1 /STO3L443 Page 2 of 5 <br /> Copyright 2002,Kleinfelder, Inc. August 18, 2003 <br />