SITE INFORMATION AND CORRESPONDENCE

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CLEANUP AND ABATEMENT ORDS .JO. R5-2011- -4- VALLEY PACIFIC PETROLEUM SERVICES INC. 930 VICTOR ROAD, LODI, SAN JOAQUIN COUNTY 15. In December 1995, Woolsey advanced boring SB-10 to install MW-10 off-site at 932 Victor Road. Woolsey observed a petroleum hydrocarbon odor in a grab groundwater sample collected from SB-10. Therefore, Woolsey completed MW-10 in boring SB-11 , which is further to the southeast than SB-10. Woolsey developed and sampled MW-10. The results were ND for TPHg, TPHd, and BTEX. Woolsey also detected elevated levels of BTEX and TPHg in MW-4, MW-7, and MW-9 at the same time that they sampled MW-10. There was insufficient water in MW-1, MW-2, MW-3, MW-5 and MW-6. Therefore, Woolsey did not sample these wells. There was LPH in MW-8. 16. In January 2001, Woolsey abandoned MW-1, which had a total depth of 46.5 feet but was often dry, and replaced it with well MW-1 D to a depth of 100 feet bgs. At that time, the flow gradient varied from southeast to southwest but primarily flowed to the south. 17. In June 2001, Board staff issued Monitoring and Reporting Program (MRP) No. 5-10- 841 . At the time, Woolsey Oil stored solvents in a 275-gallon tank. Therefore, the MRP includes monitoring for volatile organic compounds (VOCs). In August 2002, Board staff rescinded MRP No. 5-10-841 and issued MRP No. R5-2002-0827 to optimize monitoring at the Site. 18. In January 2004, Woolsey abandoned MW-9, where they had recently observed LPH, and replaced it with MW-9R, which was screened within a deeper water bearing unit at 55-to-75 feet bgs. In October 2005, Woolsey deepened persistently dry monitoring wells MW-2 through MW-5; replaced MW-6 with MW-6R, which is screened from 45-to-65 feet bgs; and installed MW-11. Around this time, Woolsey sold the facility and the name of the facility was changed to reflect the new owners; Valley Pacific Petroleum Services (Valley Pacific). 19. In August 2006, Valley Pacific installed a Keck "Spoiler" hydrocarbon recovery system in well MW-8 to recover LPH, The Spoiler, however, malfunctioned and Valley Pacific staff continued to hand bail LPH from MW-8 and MW-9R. Valley Pacific stores the LPH/groundwater mixture on site. Hazardous waste recyclers, Evergreen Environmental Inc. and American Valley Waste Oil, Inc. periodically haul off the LPH/groundwater mixture offsite. In July 2007, Board staff requested a Feasibility Study to select a method to cleanup soil and groundwater at the Site. 20. In January 2008, Valley Pacific installed monitoring wells MW-12 and MW-13 upgradient and at the southeastern portion of the Site, respectively. In April 2008, Valley Pacific submitted LPH samples from MW-6R, MW-8, and MW-9R to a laboratory for fingerprinting. The analytical results showed that LPH at the Site consisted of a mixture of degraded gasoline and high sulfur diesel, indicating that the release was likely not recent. 21. Board staff repeated the request for the Feasibility Study in a 13267 Order dated 23 May 2008. During a site visit on 3 July 2008, Board staff photographed red-dyed off-road diesel spilled on the ground surface at the AGTs. Staff discussed this observation with Valley Pacific, which indicated that they would modify future loading practices to minimize future spills.