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`4 S;ATE OF CALIFORNIA �,_. EJIAN,Governor f CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD— CENTRAL VALLEY REGION 3443 ROUTIER ROAD SACRAMENTO,CA 95827-3098 MAR 2 9 1.789 tnpn i } ENVIRONMENTAL HcA-TH 27 March 1989 PERMIT/SERVICES CERTIFIED MAIL P 839 062 351 Mr. Kyle Christie ARCO Products Company 2000 Alameda de las Pulgas P.O. Box 5811 San Mateo, CA 94403 REVIEW OF MEETING AND-WORK YLAN !7OR-SOIL:ANA.- TIER-INVES.T_IOAT_ION AT ARCO STATION 434, 501 KETTLEMAN LANE, LODI, SAN JOAQUIN COUNTY I Thank you for meeting with Regional Board staff on 10 March 1989 to discuss our procedures and ARCO's progress for investigating and preparing to mitigate contamination on their sites. At the meeting, you submitted a work plan for soil and ground water investigative work to be conducted at the 501 Kettleman Lane station for our review. You also told us of the efforts by ARCO to develop a new municipal well for the City of Lodi to replace City Well 12, now out of commission due to the hydrocarbon release at your site. We support that endeavor. We have reviewed the work plan and have specific comments on each of the three components of the work plan which will be discussed separately below. Before proceeding to our comments, we want to dearly state what we expect to see accomplished with_this proposed work. First, the lateral and vertical extent of contaminated soil is to be completely defined and a Soil Remediation Proposal (SRP) is to/ be developed. Secondly, the lateral and vertical extent of the ground water hydrocarbon plume is to be Idefined and the evidence is to be presented in a complete and comprehensive Problem Assessment Report (PAR) . This investigative work is to be completed prior to the development of a ground water remediation system. Our comments on the three parts of the 10 March 1989 work plan are as follows: SOIL CHARACTERIZATION WORK The soil characterization work plan is generally acceptable to us, but the following comments are to addressed in a devised work plan to be submitted to us and the San Joaquin Local Health District (SJLHD) by 7 April 1989. 1. An additional boring(s) is needed to define the extent of soil contamination west of the pump islands. A soil sample collected at approximately 50 feet below the surface from soil boring B-2 contained benzene at 1800 ppb and total petroleum hydrocarbons at 3600 ppm. How far west and north of B-2 does soil contamination extend? Sand layers may be acting as conduits for latera migration of hydrocarbons which is to be taken into consideration when conducting this investigation.