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Brown and Caldwell v Consultants 723 5 Street Sacramento EI t California 95814-7092 (916)444-0123 FAX(916)444-8437 J U L 2 9 1991 ENVIRONMENTAL HEALTH July 26, 1991 PERMIT/SERVICES Ms. Laurie A. Cotulla, Program Manager Environmental Health Division Public Health Services San Joaquin County Post Office Box 2009 Stockton, California 95201 017-3258-0313 Subject: ARCO Retail Facility 6080, 85 E. Louise Avenue, Lathrop, California Dear Ms. Cotulla: On behalf of ARCO Products Company (ARCO), this letter is in response to your letter of June 7, 1991 to Mr. Kyle Christie, referencing a Problem Assessment Report dated June 3, 1988, and Final Site Investigation Recommendations dated August 8, 1988. You stated that your agency had finally reviewed those reports. You requested that ARCO submit a quarterly report, as required by Section 2652(d)of the California Underground Storage Tank Regulations(CCR,Title 23, Subchapter 16), showing or discussing several items. You requested that one of the existing monitoring wells be verified to be located downgradient of"the source of contamination." You requested that the quarterly report be submitted to your office by July 28, 1991. I will address each of your comments or requests individually. • Quarterly reports: Section 2652(d) of CCR, Title 23, Subchapter 16 states "Until cleanup is complete the operator or permittee shall submit reports ...... The key word in the section is "cleanup." Since there is nothing to "clean up," there have been no cleanup activities ongoing at this site. Therefore, quarterly reports are not required under Section 2652(d). As stated in the reports referenced in your June 7, 1991 letter, petroleum hydrocarbons were non-detectable in all but two samples taken at the site. Those two samples were soil samples which showed concentrations of total petroleum hydrocarbons of 29 and 10 milligrams per kilogram (mg/kg),concentrations which can be found in soil samples collected at any operating retail facility and are not indicative of soil contamination. Groundwater samples collected from three monitoring wells at the site on April 27, 1987, December 28, 1987 and July 8, 1988, revealed no detectable petroleum hydrocarbons. • Status of investigation and cleanup activities: Since there is nothing at the site to investigate or to clean up, there has been no investigation at the site since 1988. There have been no cleanup activities at the site.