SITE INFORMATION AND CORRESPONDENCE

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Fredric Clarke page 2 to 1111 N. Union Street, Stockton, on September 9, 1993 , that the soil had been stockpiled behind the building (west of the building) and when PHS/EHD staff went to that site on November 4, 1994 the soil stockpile had been moved to the side of the building (south of the building) . A review of PHS/EHD staff inspection reports revealed that on May 25, 1993, the amount of soil estimated to be stockpiled at 729 S . Commerce Street, Stockton, was 900 to 1000 cubic yards; whereas the amount of soil estimated to be stockpiled at 1111 N. Union Street, Stockton on September 9, 1993 was 1300 cubic yards . In a letter dated March 8, 1994, which PHS/EHD did not receive until November 7, 1994, John Cummings stated that there was low levels of TPH-gasoline and BTEX in the soil . Please find enclosed a letter from California Laboratory Services dated March 11, 1993 on the soil sample obtained at the time the underground storage tanks were removed stating the sample had to be diluted and the report limits raised because of the high concentration of gasoline present . Also enclosed are copies of laboratory reports from Sparger Technology on soil samples collected after further excavation of the tank pit on April 16, 1993 . These samples also required dilution and raised reporting limits . The reason the tank pit was further excavated in May 1993 was that the soil was highly contaminated. As previously discussed in the meeting on November 4 , 1994, soil was moved from 729 S . Commerce Street, Stockton and brought back to the site by Falcon Energy on May 25, 1993 . A site visit to 1111 N. Union Street, Stockton by PHS/EHD staff on January 10, 1995, revealed that there is a small amount of soil remaining there . Since questions remain on the soil taken from Commerce Street to Union Street and then to 7735 S. Hwy 99, Stockton, a properly registered or certified professional must submit a random sampling plan for the soil at 7735 S . Hwy 99, Stockton. U.S. - E. P.A. Test Methods for Evaluating Solid Waste (SW 846) should be used as a guide in developing the sampling plan. With the recent amount of rainfall in this area both the native soil beneath and the soil imported from 1111 N. Union Street, Stockton, should be evaluated for contaminants . As guidance for the number of samples to be analyzed be advised that PHS/EHD requests discrete sampling of stockpiles at a ratio of one sample per 25 cubic yards or in the case of excavation or piping sampling for underground storage tank investigations one sample per 20 lineal feet . The samples should be analyzed for metals, TPH-gasoline, TPH- diesel, BTEX, and clorinated solvents using the appropriate test methods listed in Table 2 (copy enclosed) of the Tri-Regional Board