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Darin Rouse, EXXON#7-3708 page 2 2705 Country Club Blvd., Stockton. All areas at this site having only shallow data where the deepest soil sample is impacted by petroleum must have the vertical extent of the contamination defined. If deep soil contamination is present in the new well locations, the lateral extent of this soil plume is to be delineated also. Evaluations for the need for remediation or concurrence for'No Further Action" can only occur after the Lite has been completely assessed and the plumes delineated. PHS-EHD will require this phase of investigation to include the collection of soil samples from at least 15' bgs to, and including, 25' bgs. In addition to the two new 2" monitoring wells PHS-EHD requires, additional soil borings should be included for soil sample collection to 25' bgs in areas where the vertical extent has not been defined. This soil data is needed to support conclusions of vertical and lateral soil definition and to provide for the mass balance calculations needed in a closure report before any "No Further Action" request can be evaluated. It should be noted here that the detection of petroleum in the groundwater at the new well locations may require additional investigation in the area down-gradient of the contaminated groundwater wells. PHS-EHD has not ruled out the need for offsite "MW 9" to the north of the old UST pit. Please prepare for this contingency by contacting Mr. Charles G. Patmon III, the landowner of the apartments, at(209) 951-4391 and secure an access agreement from him. Please be prepared to install this well in a short period of time as directed by PHS-EHD. The work plan is not approved as submitted. Please evaluate the site conditions and incorporate the above noted items in a new work plan. The replacement well for MW-7 is not needed at this time. If EXXON insists on providing a well in this area with the correct screened interval, an additional 2" PVC monitoring well may be placed in the near proximity of MW-7 and constructed as noted above. Please submit the boring permit application and $89 fee with the work plan. You may contact Michael Infuma at (209) 468-3454 if you have any questions. Donna Heran, REHS, Director Environmental Health Division Michael J. Infuma Jr., Senior RENS Margare Lagorio, REHS LOP/Site Mitigation Unit IV Supervisor MI/ c: CVRWQCB —Mark List, Sacramento. c: SWRCB CUF—Sandy Gill, Sacramento. ✓c: Delta Envir—J. Brownell, 3164 Gold Camp Dr, #200, Rancho Cordova, 95670. c: Patmon Company—Charles Patmon, 1919 Grand Canal, #A1, Stockton, 95207.