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GROUND ZERO ANALYSIS, INC. <br /> 1 14 Main Street <br /> Escalon, California 95320 <br /> Telephone: (209) 838-9888 <br /> Facsimile: (209) 838-9883 <br /> May 29, 1998 <br /> Mr. Jacques S. Whitfield, Esq. <br /> Thomas M. Griffen Law Offices <br /> 6130 Freeport Blvd., Ste. 100 <br /> Sacramento, CA 95822-3520 <br /> Subject: People vs. Roy's Towing, 3570 E. Miner Ave., Stockton, CA <br /> Transmittal of Draft Removal Action Workplan <br /> Dear Mr. Whitfield: <br /> Enclosed as per your instructions please find three copies of the subject Workplan. The Workplan describes the <br /> remedial action for soil contamination at the site, provides a preliminary cost estimate for the action and a <br /> preliminary schedule for completion of the work. Per your understandings with Mr. David Irey, the remedial action <br /> selected for implementation is a combination of insitu treatment and capping (paving). <br /> Although it may be inappropriate for me to express myself here, I want to reiterate my opinion that the action <br /> selected for the site is not at all the most cost effective and provides only the slightest incremental benefit over <br /> capping alone. In point of fact, if any regulatory agency (instead of the DA's office) were calling the shots there <br /> would be no requirement to treat the soil or excavate the material. The concentrations of lead at the site are below <br /> the PRG values used by the United States and the State of California to define a potential health risk. The lead is <br /> insoluble under environmental conditions,has not and will not migrate to groundwater. Even San Joaquin County <br /> PHS/EHD uses 1,000 ppm as a cleanup value at other contaminated properties in the City of Stockton. <br /> If the remedy for soil contamination is intended as punishment then so be it. But, if the Court is concerned simply <br /> with enforcing appropriate cleanup per the requirements and specifications of applicable laws and regulations then <br /> the remedy prescribed is overkill. <br /> As we discussed, I have spoken informally with Cal EPA, DTSC about this situation. Unless you instruct me <br /> otherwise I will try to obtain an Amicus Curiae or at least an opinion addressed to me. <br /> If you have any questions or comments please contact me at your convenience. <br /> Respectfully, <br /> Ground Zero Analysis, Inc. <br /> Gregory P. Stahl, RG 5023 <br /> CA Certified Hydrogeologist No. 264 <br /> cc: Mr. and Mrs. Knoll <br />