REMOVAL_1996 - Laserfiche WebLink

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An investigation has been underway at this site since 1993 and recent conclusions reached by ARCO's consultant, EMCON, suggested that sources from off site have impacted the groundwater beneath the ARCO site. In order to verify soil conditions above the groundwater on the ARCO site, it was very important for PHS-EHD to visualize the actual conditions of the soil and the piping in the original trenches before they were removed. This was not possible because your operator removed and destroyed any evidence of the original conditions. PHS-EHD understands some of the time constraints placed upon removal activities, but strongly disapproves with any activity that removes or destroys any UGT or associated piping before the required approval of the PHS-EHD field personnel. The backhoe operator should have realized that removing the islands was damaging the piping and that he should have stopped this activity. By continuing to remove the islands, disturbing the original soil conditions, and destroying the piping, you have placed your client, ARCO , in a position that will require them to conduct further investigations to verify and support conclusions that this tank pull was designed to accomplish. PHS-EHD considers your field activities prior to the appointment time inappropriate and lacking in judgment. The lack of field supervision by your company during this tank removal has contributed to this problem and PHS-EHD has documented this unacceptable activity in your contractor file. In order to avoid any future misunderstandings, PHS-EHD hereby directs you to not remove, damage, or disturb any underground tank , piping, or trenches without a representative of PHS-EHD on site (California Underground Tank Regulations, Title 23, Section 2672 (d), San Joaquin County PHS-EHD UGT Permit Regulations). Donna Heron, REHS, Director Environmental Health Division Michael Infurna, Se or REHS Diane M. Hinson, REHS Site Mitigation Unit Supervisor MI c: ARCO Products - Kyle Christie PHS-EHD Contractor File David Irey - District Attorney's office l!/