SITE INFORMATION AND CORRESPONDENCE

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MORTHOI.E & ZEPPETEr.LO Mr. Michael Infurna September 20, 1993 Page 2 First, on June 25, 1993, GeoAudit submitted its work plan for the additional site investigation requested by the County. Among other tasks, GeoAudit proposed to drill one slant boring to a depth of 36 feet to investigate the northern limit of soil contamination detected at Monitoring Well Four (MW-4) . After reviewing the work plan, you asked why GeoAudit had not proposed a second slant boring, at a shallower angle, to a depth of 20 feet. You had apparently decided that it might be useful to drill two slant borings even though the County's letter to Mr. Reade, dated April. 15, 1993, requested only a single slant baring to 36 feet. When GeoAudit noted the terms of the County's April 15th letter, you did not pursue requiring the second slant boring. Second, in discussing the proposed work plan with you, GeoAudit's geologist, Mr. Vic Chevren, suggested that, in addition to the slant boring, it would be productive to drill a vertical boring south of MW-4. You agreed that such a boring would determine whether contamination exists between MW-4 and the area formerly occupied by the fuel tank pit, and, after obtaining Ms. Reade's approval, GeoAudit revised the work plan to include this task. While this work may have been appropriate, we note that the County had previously declined to accept a similar proposal made by the Reades to install a monitoring well and collect additional soil samples south of MW-4 . ,See Workplan for the Blockbuster Video/Yellow Submarine Site, 140 West Harding Way, Stockton, California, prepared by Greg Mello (Feb. 28, 1993) , at 11-13 . There is no indication as to why the County apparently changed its position regarding this work. Finally, and perhaps most troubling, in discussions with Mr. Chevren, you acknowledgged Ms. Reade's concern that the County appearto be "piecemealing" the site investigation. The practice of determining the need for further investigation on an ad hoc basis, depending upon the results of discrete and limited prior tasks, is reportedly intended to keep the Reades in compliance with County requirements and, thereby, maintain their eligibility to participate in the Underground Storage Tank Cleanup Fund ("Cleanup Fund") . While we appreciate your willingness to work with the Reades, this approach is simply unacceptable. Particularly now that the Cleanup Fund has issued a letter of commitment for this site, the investigation must focus on addressing applicable regulatory requirements and proceed in both a coordinated and cost-effective manner. Moreover, any concerns regarding compliance may be accommodated through the development of a reasonable compliance schedule.