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a <br /> workplan for further soil removal . <br /> 1 March 22, 1991 Workplan submitted by JTM <br /> May 8, 1991 - Additional soil excavation performed under the. <br /> direction of Dennis Allen, C.E.G. Representatives of both the <br /> San Joaquin Co. EHD & the State RWQCB were present during <br /> portions of the work. <br /> ? June 12, 1991 - Groundwater Investigation Report submitted to <br /> County EHD by WJH, which concluded. . "that .'the contamination <br /> originally found was from casual spills at' the. surf ace and that <br /> the groundwater has not been impacted.;" <br /> t <br /> August 19, 1991 - Correspondence from the County EHD in response <br /> to the SAR stated that "although there app�ears; to be no signifi- <br /> cant soil contamination, the quality of the groundwater beneath <br /> downgradient from the former underground storage tank cannot be f <br /> determined from a 'grab " sample. " <br /> I find the position of your staff rather hard to understand in <br /> view of the fact that field procedures were properly done under <br /> the supervision of a well qualified geologist, jand the Laboratory <br /> results showed that all soil' & water samples were below detection <br /> limits. I 'm sure that the EHD would like io have as many moni- <br /> toring points as possible in the County in! order to develop a <br /> large data base. However, that was not the intend of the law, <br /> and is certainly not justified in this case. As Mr. Allen <br /> discussed so thoroughly in his memo, fa copy o- which is attached <br /> to this letter, ) the "grab" sample taken at this site is a far <br /> superior technique for analyzing possible igater contamination. <br /> That is especially true in this situation -because tidal action <br /> causes the groundwater to move vertically up and down through the <br /> ' sail , allowing the water to pickup any possible contamination. <br /> ' <br /> Since analysis of both the soil and water showd no such contami- <br /> nation, the obvious conclusion. i.s -.that both _are_clean. <br /> ir _ . <br /> On behalf of our client, we would respectfully.' request that your <br /> staff review this site, and alter the Countys position an <br /> requiring the placement of monitoring wells. <br /> Sinc#ort <br /> lam' <br /> Wm. ter & Associates <br /> encl <br /> cc: f Stockton <br /> 1. <br />