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J. Hunter & Assock2les 2220 Loma Vista Dr. Registered Geologists Sacramento, CA 95825 Petroleum & Mineral Appraisers (916) 972-7941 FAX (916) 972-1683 I r November 6, 1997 Donna Heran, RENS, Director Environmental Heath Division San Joaquin Co. Public Health Services 304 East Weber Avenue, Third Floor Stockton, CA 95202 RE: EHD correspondence dated 10/21/1997 to Manuel &Mary Sanchez - 1876 Country Club Blvd., Stockton We are greatly concerned about the change in policy being implemented by the EHD as discussed in the above letter. The requirement that the Sanchez's must now show that contamination has not penetrated to 40' bgl is not justified based upon voluminous data gathered to date. Although significant levels of gasoline compounds exist beneath the site, the lateral limits have been fully defined and are restricted to a very small area beneath the sites of the removed UST's and pump dispensers. Soil samples taken at 25' bgl in two of the monitoring wells were below detection limits for all tested substances. Since the UST's were removed in 1989, the levels of BTEX & TPHg have remained fairly constant since monitoring began. This indicates that there has been no vertical movement of the petroleum products below that depth. Requiring that the owners risk the possibility of breaching that confined area and carrying contamination deeper into clean sediments& aquifers is unsound geologic& engineering practice. Although there are techniques in use which minimize such cross-contamination, they are certainly not foolproof. We do not see any evidence to support risking the possibility of spreading the contamination deeper at this site. The above referenced letter states ... "PHS-EHD regrets any inconvenience caused by this newest requirement."... and follows that with a veiled threat that non-compliance could jeopardize the owners' claims for reimbursement. It is unfortunate that the County EHD feels the need to support their positions in such a manner, As required by the County EHD staff, we have spent considerable time and expense in preparing and submitting a workplan for removing the contaminated soil which exists beneath the site. A comprehensive analysis of options revealed that this was the most cost- effective technique for reducing levels of contaminants to acceptable levels. We have not yet billed our client for that work, but hope that those costs will be approved by the State Cleanup Fund staff, since they were incurred under County directives prior to the new requirements. 1