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AWL Guidelines for Tank Removal May 15, 1990 San Joaquin County, California AGS 30041-1 without further sampling after excavating. That staff member was not sure two borings would be sufficient. We were then directed to the permit department. Your staff personnel informed us that SJPHS guidelines may not allow us to install new tanks in the proposed area if (1) laboratory analyses collected from the bottom of the old tank cavity indicate the presence of hydrocarbons and (2) if evidence indicates the hydrocarbons extend beyond the limits of the excavation of the former tank cavity in the direction of the new tank cavity, even if soil borings drilled in the proposed tank cavity indicate hydrocarbons are not present in the soil. We were also informed that the excavation beneath the former tanks cannot extend further than 4 feet below the bottom of the tank cavity even if that depth is within the safe operating limits of the excavating equipment. In our opinion your staff is not consistent on answering our questions. We have had difficulty understanding your organizational structure and the responsibility of each group within the organization with a general question that applies to a site where (1) there is no evidence of hydrocarbons, (2) hydrocarbons are known to exist and (3) a site that is in the Pilot Program. Below is a list of documents we have. We do not feel these address our concerns. o Application for Permit to Close Underground Storage Tanks Storing Hazardous Materials, dated December 1988. o Appendix A of the Tri-Regional Recommendations, and the Leaking Underground Fuel Tank Manual. o Draft Guidelines for Re-Excavation Workplan for UGST Soil Contamination and Addressing Soil Contamination Problems. and Addressing Soil Contamination Problems, dated October 20, 1988. o Guidelines for the Installation of New UGST at Sites With Documented Soil And/Or Groundwater Contamination dated September 21, 1989; o Open Memorandum From San Joaquin Local Health District, dated November 1988. o Subsurface Investigative Formats (no date) - o Regional Board Staff Recommendations for Initial Evaluation and Investigation of Underground Tanks (Tri-Regional Recommendations) At ARCO's request, we are holding the work plans for the planned tank removal until we understand your guidelines so that major rewriting or delays will not be necessary. We Appiieo' GeoSysteins