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April 11, 1996 L Page 3 activities have indicated that the later generation of underground storage tanks, in the west central portion of the site, are no longer present. Additionally, the westernmost of the first generation of storage tanks, located in the northern portion of the site, appears to have been removed. Two underground storage tanks have been shown to remain beneath the sidewalk adjacent to Eleventh Street, iri the north central portion of-the site(Figure 1). As indicated previously, these tanks appear to be the easternmost tanks of the original fuel storage tank cluster which was in service from approximately 1921 to 1950. The tanks remaining in place are of 550-gallon capacity, single-walled steel construction, and were apparently used to store leaded gasoline. These tanks were observed in detail in exploratory excavation TP-3 on June 26, 1995. Within TP-3 the tank tops were encountered at a depth of approximately 4 feet below ground surface. RATIONALE FOR CLOSURE IN PLACE Current site conditions prohibit the removal of the two remaining storage tanks. The rationale for in-place closure of the tanks is presented below. • The remaining tanks are located almost entirely under the Eleventh Street sidewalk, as shown on Figure 1. Due to the recent replacement of the Eleventh Street sidewalk, the City of Tracy Department of Public Works (TDPW) has established a three year moratorium on street excavation permits for Eleventh-Street. In a telephone conversation with Mr. Mark Thrailkill of the TDPW on February 13, 1996, Mr. Thrailkill indicated that a permit would not be issued for the cutting of the Eleventh Street sidewalk (Attachment Q. • A Pacific Gas and Electric Company (PG&E) underground electric conduit is located beneath the Eleventh Street sidewalk, adjacent to the two remaining fuel tanks. The locations of this conduit and other underground and aboveground utilities are indicated on Figure 2. The exact relationship between the position of the PG&E conduit and the locations of the tanks is unclear, because the sidewalk has not been penetrated by exploratory excavation activities. The removal of the tanks may jeopardize the PG&E conduit, or create unsafe conditions. PROPOSED SCOPE OF WORK The proper in-place abandonment of the two remaining underground fuel storage tanks will be performed according to the following procedures. All appropriate permits will be secured prior to field work. All personnel involved in the excavation and sampling activities will be appropriately trained according to California Occupational Safety and 3100971 B\TANK W P.D0C