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Harding Lawson Assn iatas May 23, 1991 17060, 024 . 03 Mr. Walter Lubcke Southland Corporation Page 2 HLA prepared a Problem Assessment Report dated January 1989 for this site and Southland submitted it to the Central Valley Regional Water Quality Control Board (CVRWQCB) and the SJCPHS. That report presented the results of site characterization and a feasibility study, along with recommendations for remediation. The results of HLA's Problem Assessment Report indicated that the "zero line" that indicated no detectable petroleum hydrocarbons in soil or groundwater was contained almost entirely on site. This zero line was established by soil borings and groundwater monitoring wells, and confirmed in HLA's report dated May 8, 1989. The off-site spread of the hydrocarbon plume was limited to part of Huffman Avenue, east of the site, and onto the adjacent lot to the north of the site. A remediation plan for this site was proposed in an HLA document dated January 9, 1989, and submitted the CVRWQCB and the SJCPHS. Implementation of the plan has been delayed because the CVRWQCB and the SJCPHS have not approved the proposed remedial alternative. The SJCPHS also refused to grant permission to install the proposed system. On this basis, the Southland Corporation decided to suspend remedial activities until approval from the regulatory agencies are obtained for the remedial systems proposed. (See Southland's Letter to the CVRWQCB dated February 10, 1989 . ) Because of the two years that have passed since HLA's most recent monitoring, we believe that a year of groundwater monitoring should be performed before reconsidering remediation at this site. Under separate cover, we are transmitting a proposal to provide quarterly monitoring and reporting for one year. Response To Comment No. 7 Of The SJCPHS Letter This SJCPHS Comment No. 7 refers to the procedure of transporting soil and groundwater samples in a cooled ice chest at 4 degrees Centigrade. It is the standard practice of HLA and others in the consulting industry to use ice chests that are cooled with "blue ice" without freezing the samples. It is not the standard practice to use refrigerated containers that maintain a constant temperature of 4°C. All soil and groundwater samples collected doing this investigation were transported in such a cooled ice chest, from the time of collection until the time of arrival at the chemical testing laboratory.