SITE INFORMATION AND CORRESPONDENCE

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Mr. Carl Navarra 7500 W. Eleventh Street ` Page 3 of 4 Regarding previous disapproval of the remedial design proposed by TSJCI, EHD wishes to clarify several points: • During the 22 July 2002 meeting between TSJCI and EHD, the terms 'trench' or 'cut-off trench' were not used, rather a large excavation with pond-like features was described. EHD recognizes that a trench is a subcategory of excavations, but the proposed excavation at that time was to be 10 feet wide, not the currently proposed 4 feet. • In the WP, TSJCI used the quote "it has not been done before in San Joaquin County" out of context stating the proposed remediation system would therefore not get agency approval. Other than as part of another activity, such as tank removal — like on-your site, excavation has not been proposed or utilized to remediate LNAPL sites in San Joaquin County, and EHD has no knowledge of its use as an approved primary remediation plan elsewhere. The statement was actually used as the basis for a request for additional information such as case histories where excavation had been given agency approval and had successfully been utilized to specifically address an LNAPL plume. EHD could then compare site characteristics and evaluate the adequacy of the approach for your site. No specific, detailed information has been provided to EHD for such an evaluation. Based on such information being provided for other remediation proposals for other sites, EHD has approved remediation plans that had "not been done before in San Joaquin County". TSJC1's request for review by a professional engineer with various qualifications is being denied at this point in time. Clearly, TSJCI has missed the main concerns expressed by EHD in past meetings and directive letters. The engineering aspects have not been in question, but as noted above, E,HD has been seeking the IIF justification, based on a plume model verified by field data, for the expense expenditure. None of the principles, equations or concepts presented by TSJCI has been beyond the experience or understanding of EHD. If such do come up, EHD has the resources of the Central Valley Regional Water Quality Control Board CVRWQCB) to draw on; and indeed this site has been much discussed with the CVRWQCB. If you disagree with this or any other decision by this agency, you have the right to appeal to the State Water Resources Control Board; EHD will send you information on the appeal process if requested by you. The other main EHD concern is implementability of the proposed remediation plan. If subsurface utilities, roadbed stability or public safety concerns do not allow deep trenching along the Eleventh Street right-of-way and the owner of the private property involved will not allow such an invasive remedial action, then this plan will be moot, and a significant expenditure of TSJCI -and EHD time and resources used devising, justifying and evaluating this remedial option will have been wasted, and may not be reimbursable by the state cleanup fund. Although TSJCI