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0 <br /> Thus far, the apparent posture of Montgomery Ward is to obfuscate the facts with respect <br /> to the release of contaminants. Further, the work plans heretofore submitted do not address <br /> the lateral and vertical extent of contamination. An undated letter, a copy of which was <br /> received by this office, June 11, 1991, from Ms. Laurie A. Cotulla addressed to Mr. Mark <br /> Gilmartin re:Montgomery Ward,5400 Pacific Avenue, Stockton,California, Site Code 2163, <br /> therein indicated concerns of the Environmental Health Division, including among other <br /> changes: <br /> (1) a closure plan to be submitted by July 23, 1991 for the removal of the <br /> underground concrete slab and all product piping and; <br /> (2) a work plan to be submitted by July 23, 1991 to define the extent of soil <br /> contamination and to determine if ground water has been impacted. <br /> Indicative of its strategy, Montgomery Ward has delayed providing such work plans. The <br /> most recently submitted work plans do not provide an adequate method of defining, the <br /> extent of contamination nor do they it address the issue of ground water contamination. <br /> Roy Weston, Inc., an environmental consulting firm, hired by Stone Bros. and Associates to <br /> review the proposals for investigation and remediation of the Montgomery Wards site, has <br /> made several recommendations described in a letter dated November 22, 1991. A coy of <br /> this letter is attached hereto and incorporated herein by reference. <br /> It is the position of Stone Bros. and Associates that any plan of investigation and <br /> remediation which does not incorporate, as a minimum, the recommendations made ' the <br /> attached letter is insufficient. It is my belief that these recommendations have been <br /> previously made to your office. Stone Bros. position has been, continues to be and will be <br /> that the concrete slab and the fuel product piping,both of which remain buried beneath the <br /> parking lot should be removed, disposed of, and sufficient soil and water samples collected <br /> to determine the lateral and vertical extent, of soil or ground water contamination. Until <br /> this aspect of the plan of investigation and remediation is thoroughly explored, Stone Bros. <br /> and Associates position will be that such investigative plan and/or remediation program is <br /> deficient. <br /> Yours very t y, <br /> Theodore I. Wittmayer <br /> ja <br /> Enclosures (2) <br /> cc: Stone Bros. and Associates <br /> Straw and Gilmartin <br />