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• Ms. Lori Duncan <br /> November 11,2004 <br /> Page 3 of 3 <br /> removed from the area. Confirmation soil samples were analyzed for the presence of petroleum <br /> hydrocarbons and VOCs. 14 of the 17 samples contained PCE, at concentrations ranging from 24 <br /> ppb to 680 ppb. <br /> Comments on Request to Submit a Workplan for Additional Investigation <br /> SJC/EHD requested a workplan from Gene Gabbard, Inc. by December 17, 2004 to continue the <br /> investigation of the vertical and lateral extent of the contamination present beneath the site. As documented <br /> above,there is ample data documenting that significant concentrations of PCE are present in soil beneath the <br /> Unifirst site. At least 62 soil samples were collected as a result of impacted soil observed at the site and/or <br /> removal of USTs, as documented in a September 24, 2004 summary report prepared by Environmental <br /> Engineering& Contracting (EEC) of Santa Ana, California. The report states that the site of the Unifirst <br /> facility previously housed a dry cleaner from the 1920s through 2002 and that PCE was used at the dry <br /> cleaner from 1948 through 1983. <br /> Of the 62 soil samples collected at the Unifirst facility, 57 were analyzed for VOCs by EPA 8260, and 36 <br /> contained detectable concentrations of PCE. PCE was detected as high as 680 ppb in shallow soil, as <br /> high as 73 ppb at a depth of 15 feet bgs, and as high as 39 ppb at a depth of 20 feet bgs. No groundwater <br /> samples were collected even though the shallow water table has been measured at less than 22 feet bgs <br /> (December 2000)at the Gabbard site. <br /> Based upon the information presented herein it appears unreasonable for Gene Gabbard, Inc. to continue <br /> additional subsurface investigation related to PCE until the lateral and vertical extent of PCE <br /> contamination from the Unifirst site is delineated. We believe there is ample data from the Unifirst site <br /> for SJC/EHD and/or CVRWQCB to require Unifirst to conduct an investigation to determine the extent of <br /> PCE contamination documented at their facility and to determine if PCE has migrated off-site in <br /> groundwater or through the sewer lines. The Gabbards would like to be kept informed of the progress of <br /> investigations related to the Unifirst site. <br /> Ground Zero will continue to remove free product motor oil from well MW3 and evaluate a more <br /> aggressive approach to accomplish this. <br /> Please feel free to call me at(209)838-9888 if you have any questions regarding this submittal. <br /> Respectfully, <br /> Ground Zero Analysis,Inc. <br /> John P. Lane <br /> CA Registered Geologist 6795 <br /> cc: Mr. James Barton,CVRWQCB <br /> Mr. Gary Gabbard <br /> Mr.John Gabbard <br /> Mr. Patrick Riddle <br /> G:\GROUNDZB\GABBARD\comspon\ehd_off fte.DOC <br />