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USNAy , 1ON .p,, ATERWORK CORP. <br /> INDUSTRIES <br /> 11 L LI <br /> AUG 12 1991 <br /> ENVIRONMENTAL HEALTH <br /> PERMIT/SERVICES <br /> August 6, 1991 <br /> Ms. Laurie Cotulla <br /> San Joaquin County Public Health Services, <br /> Environmental Health Division <br /> P.O. Box 2009 <br /> Stockton, CA 95201 <br /> Re: Genstar-Western Stone Products, 8181 E. "11th" St. , <br /> Tracy, CA 95376 (County site code 1393) <br /> Dear Ms. Cotulla: <br /> I am in receipt of your 7/10/91 letter in response to our 5/8/91 <br /> closure recommendation for the referenced site. In spite of San <br /> Joaquin County' s continued insistence that additional assessment <br /> and remediation work be undertaken we maintain that an appropriate <br /> and thorough investigation into the extent of contamination has <br /> been conducted and that an abundance of data has been gathered <br /> indicating that groundwater has not been adversely affected at the <br /> site. Repeated sampling indicates that the likelihood of future <br /> groundwater impact is essentially non-existent (Table 1 ) . <br /> It is apparent from your letter that some confusion exists <br /> regarding specifics of site hydrogeology, well placement, and soil <br /> contamination. Unfortunately, some of the points made in your <br /> letter appear to be based on erroneous data or are scientifically <br /> unsupportable. Others are not relevant. This letter attempts to <br /> address the items of concern mentioned in your letter. <br /> Regarding your contention that MW-4 is not downgradient of the tank <br /> pit, it must be admitted that from time to time this well does not <br /> occupy the "direct" downgradient location ( in the strictest <br /> definition of that term) . Due to normal fluctuations in gradient <br /> direction it would be extremely rare, if not impossible to install <br /> a monitoring well which would always be directly downgradient of a <br /> suspected contaminant source. Monitoring well MW4 was installed as <br /> closely as site features allowed to the ideal location. An <br /> examination of historical gradient (attachment 1 ) indicates that <br /> this well has ranged from approximately 2 feet to a maximum of 10 <br /> feet across gradient from the exact downgradient location. The <br /> thrust of your latest argument for an additional well appears to be <br /> WSTLR806.WP <br /> 1710 MAIN STREET . ESCALON,CA 95320 . (209) 838-3507 <br /> 2350-A WALSH AVENUE • SANTA CLARA, CA 95051 • (408)496-1249 <br />