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:t - <br /> DrFOM GREBEN & SCHgrf <br /> ATTORNEYS AT 1AW <br /> JAMES T.DUFOUR 819 F STREET <br /> JAN ADAM GREBEN SACRAMENTO,CA <br /> r- .- 95814 <br /> JEFFORY J. SCHARFF `� �J, , g . <br /> �7K [?�O. Ox 867 <br /> STEVEN A.PICCO = O,CA <br /> OCT 18 958120867 <br /> (916)553-3247 <br /> ENVIRONMENT A�, c16FF13-3250 <br /> PERMIT/SERMES <br /> October 7, 1991 <br /> Ms. Laurie A. Cotulla <br /> R.E.H.S. Program Manager <br /> San Joaquin County Public Health Services <br /> Environmental Health Division <br /> 1601 E. Hazelton Avenue <br /> Stockton, CA 95201 <br /> Re: Pacific Coast Producers 32 Tokay Street Lodi California <br /> Site Code No. 1378 <br /> Dear Ms. Cotulla: <br /> I have received your letter of September 12, 1991 regarding the former underground storage <br /> tank site at the above location and your September 11, 1991 letter regarding soil sampling at this <br /> location. In reply, I would like to present some additional facts, as I understand them, and some <br /> suggestions to help us reach closure on this matter. <br /> Our client, Pacific Coast Producers (PCP), closed the-subject underground tank on March 26, <br /> 1987 in accordance with the procedures in effect at that time and supervised by San Joaquin <br /> County Public Health Services. The tests taken at that time from the visible "hot spot" at 15 <br /> feet in the excavation indicated diesel at 9.800 mg/Kg and xylene at 109 µg/Kg. A second test <br /> at the 21 foot level indicated no detectable diesel, xylene or other analytes in the 8015 and 8020 <br /> methods employed. <br /> Based on procedures in existence at that time, it appears that the County should have issued a <br /> closure letter based on the clear results at 21 feet. Apparently, no such letter was ever issued <br /> and, because the excavation posed a safety and operational problem, it was backfilled with <br /> predominantly clean soil and capped. Your office was notified of this fact on May 1 l, 1987. <br /> It was not until a voluntary environmental audit was conducted by PCP in 1990 that it was <br /> revealed that there was no closure letter on the tank in question. On the basis of this <br /> information, PCP had attempted to update the information currently available on the site with <br /> soil sampling to identify whether any contamination was present and to verify the previous test <br /> results. <br />