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4 <br /> i <br /> ST Services ST Services <br /> a GRACE company 17000 Dallas Parkway, Suite 223 <br /> Dallas, Texas 75248 <br /> (214) 931-8065 <br /> November 3, 1986 <br /> Dir C. Leland Hall <br /> Director (� <br /> Environmental Health Division NOV ] �ytSb <br /> San Joaquin Local Health District <br /> 1601 East Hazeltin Avenue <br /> P. 0. sox 2009 ENVIROMENTAL HEALTH <br /> Stockton, CA 95201 PERMIT/SERVICES <br /> RE: UNDERGROUND TANK REMOVAL PROJECT <br /> Dear Mr. Hall: <br /> This letter responds to your letter to us dated October 24, 1986 <br /> concerning analytical results from soil sampling conducted by our consultant, <br /> Weiss Associates in May 1986. At our request, our consultant provided you with <br /> these test results in June 1986. <br /> At the outset, we believe that it is important to correct certain <br /> misstatements contained in your letter of October 24. First, we believe that <br /> analytical results from a single soil sample do not provide an adequate basis for <br /> concluding whether an "unauthorized release" has occurred. Furthermore, we <br /> do not believe that the analytical results on this soil sample demonstrate a <br /> "violation" of the California Health and Safety Code, the California Water Code <br /> or their implementing regulations. <br /> As required by these statutory and regulatory programs, we reported this <br /> information to you four months ago and requested guidance on the appropriate <br /> course of action. In the interim, we have been ready, willing and able to <br /> conduct any further investigation that the Health District might require. Since <br /> the Health District now appears to consider further characterization necessary, <br /> we will retain a qualified engineering consulting firm to submit a plan for <br /> identifying the extent of contamination, if any. We willsubmit our consultant's <br /> plan to the Health District no later than December 5, 1986. This plan will <br /> include both the testing proposal and a schedule of implementation. <br />