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American Moulding and Millwork Company* Tel (209)948-3161 <br /> P.O. Box 8220 <br /> 2801 West Lane <br /> Stockton,CA 95208 <br /> October 5, 1987 <br /> Mr. James L. Tjosvold D jpy <br /> Senior Waste Management Engineer <br /> Department of Health Services <br /> Toxic Substances Control Division <br /> 4250 Power Inn Road OCT 9987 <br /> Sacramento, California 95826 <br /> ENVIROMENTAL HEALTH <br /> Subject: DHS Site Review and Underground Storage Tank Removal FERMIT/SERVICES <br /> Dear Mr. Tjosvold: <br /> American Moulding and Millwork (AMM) has been investigating the consequences <br /> of a diesel leak from an underground storage tank for the past three years <br /> in an effort to remedy the problem. Our facility, by apparent virtue of <br /> consolidating all American Forest Product (former owner) sites under an <br /> umbrella management approach, was included on the state's Superfund list of <br /> sites. The objective was to effectively investigate the sites concurrently <br /> under a common approach and timeline. During the last several years , the <br /> DHS focused staff and priorities toward other AFP sites; little or no <br /> guidance or review occurred for the Stockton facility and little or no <br /> progress was achieved. Subsequently, the Expenditure Plan concept was <br /> adopted by DHS and because of relative priorities, the Stockton AFP site was <br /> segregated and backlogged. <br /> AMM desires to progress toward remediation as soon as possible and we do not <br /> feel it is prudent or environmentally sound to delay our activities until <br /> the Fiscal Year 1990-1991. We would appreciate your consideration and <br /> adoption of one of the following options available to DHS and AMM. <br /> (1) Delete the underground tank work from the scope of the RAP process. <br /> The lead would be relinquished to the county under the LUFT program. <br /> Other lower priority issues (i.e. ,FCP surface soil contamination) <br /> relevant to the site would be addressed by the RAP process but would <br /> be postponed until 1990. <br /> (2) Delete the underground tank work from the scope of the RAP <br /> process. The lead would be relinquished to the county under the <br /> LUFT program. AMM provides advance funding to DHS for the PCP <br /> surface soil contamination for site review and the site would be <br /> rescheduled for this fiscal year. <br /> (3) AMM provides advance funding to DHS for site review and the site <br /> would be rescheduled for this fiscal year. <br /> Our preference (2) is to exclude the LUFT scope from the RAP process. This <br /> would require a letter from DHS to San Joaquin County deleting the fuel <br /> storage tanks from the RAP scope, thereby giving the county the capacity for <br /> reviewing and approving the proposed scope of work and subsequent remedial <br /> measures. <br /> An equal opportunity employer <br />