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BOARD OF TRUSTEES James Culbertson, Pres. Patricia E. Vannuccl, Sec'y. Tommy Joyce Earl Pimentel Fern Bugbee Daniel L. Flores John D. Mast, M.D. William J. Wade Mary Anna Love September 22, 1986 SAI10OAQUIN LOCAL HEALTH DISAT SERVING City of Lodi 1601 East Hazelton Avenue, P. O. Box 2009 San Joaquin County City of Escalon Stockton, California 95201 City of Manteca 209/466-6781 City of Ripon ity of Stockton City of Tracy Jogi Khanna, M.D., M.P.H., District Health Officer San Joaquin County John Richmond Vice President - Technical Services Holly Sugar Corporation P.O. Box 1052 Colorado Springs, CO. 80901 Sanoaquin County RE: Holly Sugar Corp. 20500 Holly Drive Tracy, CA. The site assessment proposal for evaluation of the extent of contamination in he area where two underground gasoline storage tanks were removed at this facility has been re- viewed. The San Joaquin Local Health District Environmental Health Division, has no objection to the proposed plan provided the following clarifications and/or changes are included: 1. At least one of the three monitoring wells proposed in each tank area must be as close as possible to the former tank location, preferably through the areas showing highest levels of contamination at the time of tank removal. 2. Wells shall be constructed by a method which allows collection of undisturbed soil samples at 3 to 5 ft. intervals until groundwater is encountered. These samples shall be logged and described as per Sect. 2648 (t -u) of the nder- ground Storage Tank Regulations. 3. Soil samples for volatile organic compounds, shall be collected, preserved, stored, transported and analyzed by appropriate methods such as brass tubes or equivalent in split spoon or Shelby tube sampler. 4. All Samples positive on field screening shall be submitted for analysis. All other samples shall be frozen and retained for further analysis if re- quired. A minimum number of samples per boring shall be submitted for an- alysis. This number will be determined prior to starting investigation. 5. All soil samples shall be analyzed for BTX by EPA method 8020 and total hy- drocarbons by EPA method 8015 (modified). Samples from the leaded gasoline tank area shall be analyzed for tetraethyl lead and EDB. 6. The monitoring well shall be screened 20 ft. below and at least 5 ft. above lowest and highest groundwater levels. If a laterally extensive clay layer at least 5 ft. thick is encountered below the water table the well sh 11 be terminated 1-2 ft. into the clay layer. If groundwater is less than 0 ft. from the surface, the wells shall be screened high enough to intercep the interface between the saturated and unsaturated zones.