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Mr. Victor Izzo -2- NOTICE OF VIOLATION FOR INADEQUATE DETECTION MONITORING PROGRAM, CORRAL HOLLOW SANITARY LANDFILL I spoke with Todd Del Frate, briefing him on the meaning of that Finding and the long history of the site. He verbally withdrew the requirement that we submit a work plan, instead requiring that we provide the evidence that supported the conclusion by that only the deep aquifer was present beneath the southwest area. We ask that well boring logs and the findings of the Board Orders be considered adequate to support this conclusion. The drilling log for shallow aquifer well MW-4 on the east portion of the site(Figure 1), records low plasticity silty clay starting at a depth of approximately seven feet,with groundwater recorded at approximately 13 feet (log enclosed). This stratum was identified as the Corcoran formation by Emcon geologists on site at the time of drilling. I am told that a RWQCB geologist visited the site when this well was being drilled. In contrast, the drilling logs for the deep aquifer wells MW-2 and MW-7, in the southwest portion of the site,indicate the presence of sands and gravels,but not clay (log excerpts enclosed). Finally,three Board Orders (Order 89-046, 94-259 and 5-01-176, also enclosed) included Findings that the shallow aquifer was not present in the southwestern portion of our site. We have no doubt that Order Findings are (and were)made by experienced staff after careful consideration of all the evidence available at the time. We are not aware of new evidence discovered at our site since then that would cause us to question these decisions. Some of the names on the Order transmittals are familiar. I suspect this violation would not have been issued if this situation had been discussed with them. Please accept these drilling logs,these Findings, and the lack of any evidence to the contrary as sufficient basis to continue to hold the shallow aquifer monitoring system adequate and in accordance with the Board Orders. With this information, and with the submittal of the missing data disk, it seems our violation is cleared. If you have any questions,please contact me at (209) 468-8504 Sincerely, W. MICHAEL CARROLL, PE Senior Civil Engineer WMC:kb N:\1 Corral Hollow\Groundwater Monitoring\Vlzzo03-Violation.doc Enclosures c: Robert MClellon San Joaquin County Environmental Health Department Wendy Wyels, Environmental Program Manager, RWQCB LA 21850