SITE INFORMATION AND CORRESPONDENCE

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California Fuels and Aegis respectfully disagree with the expressed "no basis" position and believe there is ample justification to hold a meeting. For example, The site was operated for some fifty years as a bulk fuel storage and distribution facility prior to its decommissioning in 1988. It is located less than a quarter of a mile from the Mokelumne River. During that time, relatively high stands of groundwater have occurred within the town of Woodbridge on a number of occasions, particularly in 1986. Aegis has reported results of groundwater monitoring at the site to the CVRWQCB covering the period of May 1989 to April 1991. Results of this monitoring consistently indicated groundwater was not impacted by the petroleum hydrocarbons determined to be within soil above groundwater; since excavated to the fullest extent, both practical and sound, given the conditions existing at the site. On the basis of the accumulated monitoring data, Aegis requested of and was granted by the CVRWQCB, in July 1991, approval to abandon the then three groundwater monitoring wells located on site. Moreover, Aegis received approval from the CVRWQCB to backfill the excavation with the soil successfully treated on site by bioremediation. Both tasks were accomplished in August 1991. Aegis was preparing a request for site closure, supported by technical arguments, for submittal to the CVRWQCB when, in October 1991, the first of a series of correspondence was received from the CVRWQCB requiring further work be conducted there, including additional soil boring and sampling. Subsequent correspondence received from the CVRWQCB, up to and including the June 26, 1992, letter mentioned above, have requested ever expanding scopes of work be conducted, including installation of new groundwater monitoring wells. On behalf of California Fuels, Aegis has responded to each of the requests in a timely and forthright manner, including submittal of workplans and the previous requests for a meeting to discuss the issues. However, our responses to the CVRWQCB have merely been termed "inadequate" and each request for a meeting has been denied. California Fuels and Aegis continue to consider it imperative the meeting be held before any additional work is begun at the site, and to discuss the technical merits and rationale for as well as the scope of the additional work requested by the CVRWQCB. 89-031 W.LTR