SITE INFORMATION AND CORRESPONDENCE

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Ms. Laurie A. Cotulla October,.7, 1991 Page•2 These samples were taken, as you have noted, by a hand auger. They were never intended to 'yield undisturbed soil samples and precise records of stratigraphy," but merely repeat and verify previous results at-the 20 -foot level., .There is no practical difference between this sampling and the sampling taken`_at the bottom of an excavation. Furthermore, your Agency's procedures:allow someone other than a registered.geologist to-take samples from the bottom of .an•excavation. In this case, a registered' geologist, Gordon Alward, was employed for the - sampling: The express reason aegistered.:geologist was.used was to obtain the credibility his professional°credential- affords inthis`unique situation. V�+ith-respect�to the need.for a perm it=to ob►aiij si�ai�ow soil samples wl�ic+i'do ;.oe penet►ate to ,groundwater in an area-which,had'previously-been excavated to the same depth as indicated in your September 11, 1991 letter, this requirement does not appear to be supported by the plain _language of the-permit application (all of which is irrelevant and appears to apply to water well and monitoring well installation) and the Ordinance cited in your letter which, again, addresses vwells., -It=is.my understanding tliat Mr. Alward checked with the County and was advised that there were--no specific ermittin r uirements for shallow excavations and/or soil sampling. p P .g . � Your clarification of this matter would be app'reciate&in that.it is our practice and our client's intent to comply with every.applicable requirement.wherever work is performed. The last point I would like to raise-is a typographical error in-the report submitted to you which ,erroneously lead you to believe that a higher level of contamination exists on the site than is warranted by testing to-date., The July,11, 1991 report, "Site Remediation Update," which states that"43.8 ppm of xylene was detected in a 20-foot sample, is.in error.- The amount actually detected and reported by California.Water Labs is 43.8 .µg/Kg (or ppb). As this 1,000 times lower concentration of xylene and other values closely proximate-the results of previous testing, it was�our expectation that the County would not require further action. This result would be supported under the LUFT Manual as "a minor contamination site." [C7 of Category No. 1.1 Based on this new information.and viewed from tl;e perspective of a voluntary compliance effort - on.the part of our client, I request that you reconsider your letters of September 11 and 12, 1991 and consider the following as a means to .resolve,this current problem. 1.. :Provide us.with -your-'Agency's rationale and 'authority of permitting for this specific activity. It is our intent to comply once we understand this requirement. 2. Allow us to revise our report to correct- the typographical error and better -describe g sam lin procedure and evaluate the results. P 3. Advise us what additional work is necessary and supportable to close this matter.