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Harding Lawson Assoolates <br /> May 23, 1991 <br /> 17050, 024. 03 <br /> Mr. Walter Lubcke <br /> Southland Corporation <br /> Page 2 <br /> HLA prepared a Problem Assessment Report dated January 1989 for <br /> this site and Southland submitted it to the Central Valley <br /> Regional Water Quality Control Board (CVRWQCB) and the SJCPHS. <br /> That report presented the results of site characterization and a <br /> feasibility study, along with recommendations for remediation. <br /> The results of HLA's Problem Assessment Report indicated that <br /> the "zero line" that indicated no detectable petroleum <br /> hydrocarbons in soil or groundwater was contained almost <br /> entirely on site. This zero line was established by soil <br /> borings and groundwater monitoring wells, and confirmed in HLA's <br /> report dated May 8, 1989. The off-site spread of the <br /> hydrocarbon plume was limited to part of Huffman Avenue, east of <br /> the site, and onto the adjacent lot to the north of the site. <br /> A remediation plan for this site was proposed in an HLA document <br /> dated January 9, 1989, and submitted the CVRWQCB and the SJCPHS. <br /> Implementation of the pian has been delayed because the CVRWQCB <br /> and the SJCPHS have not approved the proposed remedial <br /> alternative. The SJCPHS also refused to grant permission to <br /> install the proposed system. On this basis, the Southland <br /> Corporation decided to suspend remedial activities until <br /> approval from the regulatory agencies are obtained for the <br /> remedial systems proposed. (See Southland's Letter to the <br /> CVRWQCB dated February 10, 1989. ) <br /> Because of the two years that have passed since HLA's most <br /> recent monitoring, we believe that a year of groundwater <br /> monitoring should be performed before reconsidering remediation <br /> at this site. Under separate cover, we are transmitting a <br /> proposal to provide quarterly monitoring and reporting for one <br /> year. <br /> Response To Comment No. 7 Of The SJCPHS, Letter <br /> This SJCPHS Comment No. 7 refers to the procedure of <br /> transporting soil and groundwater samples in a cooled ice chest <br /> at 4 degrees Centigrade. It is the standard practice of HLA and <br /> others in the consulting industry to use ice chests that are <br /> cooled with "blue ice" without freezing the samples. It is not <br /> the standard practice to use refrigerated containers that <br /> maintain a constant temperature of 4°C. All soil and <br /> groundwater samples collected doing this investigation were <br /> transported in such a cooled ice chest, from the time of <br /> collection until the time of arrival at the chemical testing <br /> laboratory. <br />