SITE INFORMATION AND CORRESPONDENCE_FILE 2

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Mr. Ken Gillies Gillies Trucking 3931 Newton Road, Stockton Page 2 of 5 The hydrogeology at the site has been well understood since October 1996; subsequent work has merely confirmed the 1996 hydrogeological interpretation and that future monitoring is unlikely to produce significant new insights in the future. Also, UEC cannot imagine any public health benefits being derived from additional attempts to locate the precise limit of soil or ground water contamination and that there has been no significant migration of the plume of impacted ground water. Therefore UEC recommended reduction of monitoring frequency from quarterly to annual and that further investigation be dropped from consideration. UEC notes that diesel contaminants have been detected in the Gullies domestic well approximately 25% of the time and has had only one event with a diesel concentration exceeding 500 ppb. UEC states that the water is not utilized for drinking and proposes that the current well not be replaced but that produced water be treated at the wellhead utilizing carbon canisters. In the 10 September 2002 letter, UEC stated their belief that EHD has 30 days to comment on recommendations under the "County-State Local Oversight Program" and that lack of written comment by EHD implies concurrence with those recommendations. Specifically, UEC believes that lack of written comment from EHD is concurrence with UEC's recommendation for no further investigation and for a monitoring frequency reduction from quarterly to annual events, with the next event in February or March 2003. UEC is mistaken. The Local Oversight Program contract contains no language specifically addressing review and comment periods for recommendations contained in quarterly reports. In the interest of minimizing environmental contamination and promoting prompt cleanup of sites, the Health & Safety Code and UST regulations do allow implementation of a work plan after submittal of the work plan before receiving regulatory approval, but implementation may not begin sooner than 60 calendar days after submittal of work plan. EHD does not believe that any of UEC's quarterly report recommendations meet any of these conditions; they do not constitute a work plan and they were not proposed to prevent environmental contamination or to promote prompt clean up of the site. EHD does not concur with these recommendations and directs that quarterly monitoring be resumed immediately. Every attempt should be made to implement the monitoring event for the third quarter of 2002 and the fourth quarter monitoring event must be implemented. Under State Water Resources Control Board Resolution No. 88-23 responsible parties may petition the State Board for review of the action or decision a local agency makes, a copy of which will be sent to you if requested. Regarding other conclusions and recommendations of the Second Quarter 2002 Report, EHD comments as follows: