Laserfiche WebLink
American <br /> Moulding&Millwork <br /> Company <br /> May 10, 1989 <br /> Page 2 <br /> downgradient well until nearly 12 years after discharge . <br /> Because of the slow groundwater velocity, the location of <br /> existing monitoring wells, the uncertainty regarding the <br /> date on which the diesel and waste oil tanks began to <br /> leak, and the failure of Dames & Moore to conduct <br /> groundwater sampling in the vicinity of these tanks, it <br /> cannot be reliably concluded that groundwater at the site <br /> has not been impacted by those discharges . While Dames & <br /> Moore cites the danger of inadvertent contamination of <br /> groundwater as the basis for not locating a monitoring <br /> well in an area containing contaminated soil, such wells <br /> are regularly installed at sites throughout California <br /> without adverse effect . Your own comments on the proposed <br /> plan notes this deficiency in the site investigation, yet <br /> nothing was ever done to correct it . <br /> The proposed remedial action plan is also inadequate <br /> because it fails to address known PCP contamination at the <br /> site . This oversight is neither explained nor justified <br /> in the plan. <br /> We are most concerned that the proposed remediation has <br /> apparently been approved by your office, at least on a <br /> tentative basis, without any input from AMMC or other <br /> members of the public . As you know, the property is <br /> identified in the Hazardous Substance Account Bond Act <br /> Expenditure Plan. Accordingly, very specific statutory <br /> safeguards apply to the Remedial Action Plan development <br /> and approval process . See Health & Safety Code § 25356 . 1 . <br /> Among these safeguards is public review and comment on the <br /> proposed plan prior to approval . At the very least, we <br /> must be given an opportunity to express our concerns and <br /> to obtain an explanation of the District ' s rationale for <br /> approving the plan. Given the facts, we also believe that <br /> the State Department of Health Services and the Central <br /> Valley Regional Water Quality Control Board would have to <br /> approve any cleanup level even approaching the one <br /> suggested by Dames & Moore . <br /> As the present owner of the property, no one is more <br /> interested in expediting cleanup of the site than AMMC. <br /> However, any cleanup must fully address all contamination <br /> at the site and ensure that human health and the <br />