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L December 2, 1997 Page 2 • Scheduling of a meeting with Tosco's consultant GeoStrategies, Inc. (GSI) to discuss the continued operation of the site SVE system. • Inclusion of analysis of all future groundwater samples by EPA Method 5260. • Reestablishment of Wells MW-1, MW-8, and MW-I I which were apparently covered by the City of Stockton during roadway construc- tion adjacent to the site. It is the opinion of Pacific Environmental Group, Inc. (PACIFIC), that the necessity of this addendum work plan is founded on the need to comply with the PHS/EHD while the case is being reviewed by the Fund, rather than on technical merit. It remains PACIFIC's technical opinion that the site is suitable for environmental closure and no further corrective action is required. Implementation of all or part of the scope of work will be pending a final response from the Fund reaarding their review of the case. During a November 24, 1997 telephone conversation, Mr. James Munch of the Fund indicated to Bob Wenzlau of PACIFIC that the Fund should provide a response within 60 days (January 23, 1998). Therefore, implementation of the scope of work should be deferred until Tosco has received a final response from the Fund. BACKGROUND In a letter dated September 12, 1997, Tosco stated their position that a single confirma- tion soil boring and replacement of one downgradient perimeter monitoring well was sufficient to meet PHS/EHD's requirements for further site assessment. In that letter, Tosco further concluded that the dissolved hydrocarbon plume appeared stable, and that based on historical groundwater monitoring data, the site should be considered as a low- risk case and reviewed for case closure by PHS/EHD. To comply with the PHS/EHD work plan request, Tosco submitted a work plan, prepared by GSI and dated Septem- ber 12, 1997, which outlined the installation of one monitoring well and one confirma- tion boring. In a letter dated September 26, 1997, PHS/EHD responded that they could not agree the dissolved hydrocarbon plume was stable and stated that additional assess- ment work would be necessary. A work plan addendum was required by October 15, 1997. In a letter dated October 15, 1997, Tosco notified PHS/EHD of its intention to proceed with a submittal to the Fund, requesting case review and closure status. In a letter to the Fund dated October 30, 1997, PACIFIC, on behalf of Tosco, requested that the Fund review the case, and provided rationale that the site is suitable for environmental closure. The Fund's review is still in progress. 3111657A',STOCKLDDC