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Steve Jerkins 404 W. Fremont Street Page 2 In the letter from PHS/EHD to Steve Jerkins (yourself) dated March 10, 1993 regarding the "Workplan for Subsurface Investigation" by Wallace-Kuhl and Associates, PHS/EHD recommended Total Lead be analyzed in addition to BTX & E and TPHg. Although the tank held Unleaded Fuel at the time of the removal it is conceivable that this tank held leaded gas at one point during its history. Therefore, lead levels need to be determined to properly develop a remediation plan that would address this contaminant. Please add lead to the constituents analyzed for in the groundwater samples. The former tank pit was reportedly over excavated on January 14, 1987 to a depth of 22 feet. The January 23, 1987 report from Applied Geosystems states "Excavation was required in the area because sampling after tank removal operations showed that hydrocarbon contamination was present in the area at levels above 1000 ppm. The results indicate that soil contaminated at levels above 1000 ppm has been removed'.." This soil was placed under plastic on an adjacent lot to prepare for aeration. During a PHS/EHD inspection on January 22, 1991, it was discovered that approximately 260 yards of soil and 55 yards of construction debris was sampled in March 1990 and transported to Holt, CA for landfilling. The results of the stockpile sampling of March 1990 have never been submitted to PHS/EHD. In your next report provide the March 1990 sample results and clarify if the soil transported to Holt was from the 1987 soil excavation contaminated with 1000 ppm of petroleum hydrocarbons. The analytical results of soil sampling conducted on October 29, 1986 confirmed soil contamination at 15 feet in B2 which was drilled 6 feet north of the excavation. The results of the 15 foot sample in B2 are TPHg 28.6 ppm, Benzene 1400 ppb, Toluene 2600 ppb, Xylene 6800 ppb, and Ethyl Benzene 500 ppb. Sampling results from the excavation conducted on January 14, 1987 indicated Total Volatile Hydrocarbons of 394 ppm in the South Wall and 569 ppm in the East Wall remaining after the excavation was completed. Applied Geosystems performed a soil vapor survey on January 13 1988, the results of which were discussed in a March 15, 1988 Applied Geosystems Report. Soil vapor surveys are useful screening tools but physical definition of the soil contamination is required. The contamination remaining in the former tank excavation and the contamination present in boring B2 indicate the need for further assessment of the remaining soil contamination. Sampling of the existing monitoring wells is to be scheduled immediately. A 48 hour notification of the sampling event is to be provided to PHS/EHD. A quarterly report including the results of the sampling should be submitted to PHS/EHD by January 15, 1994. In addition, a work plan to further investigate the extent of the soil and groundwater contamination should be submitted to PHS/EHD by January 15, 1994. If you have any questions, contact Steven Sasson, Senior REHS, at (209) 468-3459. Jogi Khana, M.D., M.P.H. Health Officer Donna Heran, REHS, Program Manager Environmental Health Division DH/SS