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r <br /> April 29, 1993 , ". : <br /> SEACOR <br /> #SAY 03 1993 Science&Engineering <br /> VIRONMENTAL HEALTH AnalysisCorporcation <br /> Ms. Laurie A. Cotulla, REHS, Program Man : if�t i- � <br /> San Joaquin County <br /> Public Health Services <br /> P.O. Box 2009 <br /> Stockton, California 95201 <br /> RE: 429 WEST LOCKEFORD STREET, LODI, CALIFORNIA, SITE CODE 1354 <br /> Dear Ms. Cotulla: <br /> On behalf of Mr. Mardee Kidd, the owner of property located at 429 West Lockeford Street in Lodi, <br /> California (site code 1354), Science & Engineering Analysis Corporation (SEACOR) is submitting this <br /> letter in response your agency's letter dated April 22, 1993. Since May 1991, Mr. Kidd has expended <br /> significant effort and money investigating and remediating a gasoline release from underground storage <br /> tanks (USTs) formerly located on the subject property. Mr. Kidd has been very proactive in addressing <br /> this problem, and in every step of the process, SEACOR and Mr. Kidd, have cooperated with your staff <br /> by submitting work plans, technical reports, quarterly status reports and verbal notifications to insure that <br /> the appropriate steps were being taken to investigate and remediate the release. We believe that the two <br /> case officers responsible for overseeing the site, Mr. Stephen Schneider and Ms. Mary Meays, will <br /> confirm Mr. Kidd's level of cooperation. <br /> However, your April 22, 1993 letter requested Mr. Kidd to drill additional soil borings to confirm <br /> completion of soil remediation. SEACOR and Mr. Kidd strongly oppose this requirement and request <br /> that you review the available information and reconsider this requirement. We believe that adequate data <br /> has been collected to demonstrate that further soil assessment and/or remediation is not necessary and that <br /> the requirement to drill more soil borings is unduly burdensome and not justified. The following is a <br /> summation of the pertinent data on which SEACOR bases it's position. <br /> In May 1991, SEACOR advanced three soil borings in the vicinity of the former USTs to assess the lateral <br /> and vertical extent of petroleum hydrocarbons in subsurface soils. Soil boring MW-IA was advanced <br /> within the limits of the former UST excavation (directly beneath former USTs) to a depth of <br /> approximately 60 feet below ground surface (bgs). This boring was subsequently completed as a <br /> groundwater monitoring well. Chemical testing results of soil samples collected from exploratory boring <br /> MW-lA indicated that elevated concentrations of total petroleum hydrocarbons as gasoline (TPHg) and <br /> benzene, toluene, ethylbenzene, and xylenes(BTEX)were present in soil samples from 20 to 35 feet bgs. <br /> A maximum TPHg concentration of 5,100 parts per million was detected in a sample collected from 25 <br /> feet bgs. <br /> Two additional exploratory soil borings (BH-1 and BH-2) were advanced on the east and west side of the <br /> former USTs at a distance of 25 and 20 feet from boring location MW-1A, respectively. Soil samples <br /> collected from soil boring BH-1 between 10 and 25 feet bgs contained no detectable TPHg or BTEX. <br /> Soil samples collected from boring BH-2 between depths of 10 to 40 feet contained no detectable TPHg <br /> at a detection limit of 1 ppm. Trace levels of benzene, toluene, and ethylbenzene (7, 27 and 10 ppb, <br /> KIDD.LTR <br /> ]SM14003-01 <br /> 90 New Montgomery Street, Suite 620, San Francisco, CA 94105 (415)882-1548Pb (415)882-4406 Fax <br />