SITE INFORMATION AND CORRESPONDENCE

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Fredric Clarke Page 2 future. This was followed up with a letter from PHS/EHD to Mr. Clarke with a copy to Mr. Cummings dated September 10, 1993, concurring that the soil was not a hazardous material, could be transported to 1111 N. Union, and requesting that PHS/EHD be notified prior to any site activities. On September 9, 1993, PHS/EHD staff verified the soil had been removed from 729 S. Commerce and that there was soil at 1111 N. Union. On a PHS/EHD inspection report approximate dimensions of the soil stockpiled at 1111 N. Union were noted. In a letter dated September 30, 1993 San Joaquin Valley Unified Air Pollution Control District (SJVUAPCD) gave Falcon Energy authorization for uncontrolled soil aeration for the soil at 1111 N. Union subject to certain conditions (copy enclosed) . On November 7, 1994, after a phone conversation between John Cummings and Margaret Lagorio, a letter was received by PHS/EHD from John Cummings dated March 8, 1994, stating that after 6 months of aeration, remediation of the soil at 1111 N. Union was complete. On February 22, 1994 Mr. Cummings obtained 8 samples from the stockpile and composited them into 2 samples for laboratory analysis. PHS/EHD was not notified of this sampling event as previously requested and did not witness it. The number of samples obtained as well as the amount and method of compositing is inadequate for the amount of soil that was stockpiled at 1111 N. Union. PHS/EHD will not honor the sample results and does not accept that the soil was clean. Since a report of the excavation activities has not been submitted by a properly registered professional, PHS/EHD staff reviewed their inspection reports completed on May 25, 1993 and September 9, 1993. It appeared that there was more soil stockpiled at 1111 N. Union than was excavated from 729 S. Commerce. PHS/EHD requested the following information: 1. The name of the company who transported the soil from 729 S. Commerce to 1111 N. Union and the amount of soil that was transported. 2. The name of the company or person who treated the soil at 1111 N. Union and whose equipment they used to treat the soil. Was a log of the daily quantity of soil aerated kept as required by SJVUAPCD? 3. The amount of soil transported from 1111 N. Union to 7735 S. Highway 99. 4. Did Mr. Clarke receive payment for his soil or did he pay to have the soil moved from 1111 N. Union to 7735 S. Highway 99? At the time of the meeting, information regarding items 1, 2, and 3 shown above could not be provided. Mr. Clarke did state that he did not receive payment for the soil nor did he expect to pay for moving of the soil from 1111 N. Union to 7735 S. Highway 99. In order to decide the number of soil samples to be collected from the soil moved to 7735 S. Highway 99 and what constituents should be analyzed for in order to properly evaluate that soil, information on items 1, 2, and 3 shown above must be provided to PHS/EHD. Please provide copies of invoices for the work provided by Falcon Energy in April and May 1993 . In addition, please provide invoices, bills of lading, or other items for the work required to aerate and transport the soil since May 25, 1993, that will provide PHS/EHD with the information we need to make effective decisions on the soil. Also provide PHS/EHD with a copy of the log required by SJVUAPCD for uncontrolled aeration. This information should be submitted to PHS/EHD by November 28, 1994. If this date cannot be met please