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PUBLIC HEALTH SERVICES ,oa��in SAN 10AQWN COUNTY )OGI KHANNA M D M P H < Heaah Officer P O Box 2009 • (1601 East l-Iazelton Avenue) • Stockton, Cahfomra 95201 4�+rroA� (209) 468-3400 CHUCK NICHOLS USA PETROLEUM CORPORATION _7_ P O BOX 1836 (! f AUG ! 9 199 SANTA MONICA CA 90406 r } RE USA Petroleum Station #65 SITE CODE: 1356 2500 W Lodi Avenue Lodi, CA San Joaquin County Public Health Services, Environmental Health Division (PHS/EHD) has completed the review of the "Quarterly Monitoring Report" dated February 20, 1992, submitted by Western Geo- Engineers and has the following comments The results from the latest round of groundwater sampling appear to be inconsistent with the field observations noted by the sampling technician The volume of water purged from the wells prior to the sampling was not the minimum of three to five well volumes as recommended in the LUFT manual Additionally, PHS/EHD was not notified of the groundwater sampling event and therefore not able to observe and verify that proper purging,sampling and handling methods were used to obtain and store the samples For all future sampling activities at the site, please provide at least 48 hours advance notification to PHS/EHD so that a representative from this office can be present. The data presented in the report indicates that the groundwater contaminant plume is migrating off-site The monitoring wells currently being used to monitor the areal extent of the plume are not providing sufficient data representative of the actual groundwater contaminant distribution and migration If the monitoring wells located at the perimeter of the plume are too far removed to effectively monitor the contaminant distribution and the migration rate of the plume, then additional monitoring wells, located closer in to the plume, may need to be installed Also, an additional groundwater monitoring point needs to be installed in the area of monitoring wells S-1 and S-2,which are now dry Please submit a workplan for the installation of additional monitoring wells to PHS/EHD by September 21, 1992. In addition, by September 21, 1992, monitoring well 4, which has been paved over, must be found and either restored to operating condition or properly destroyed under permit from this office If monitoring well 4 is destroyed, another well will have to be drilled to tape it's place in order to effectively monitor the groundwater, as stated above PHS/EHD has stated, in a letter from this office to USA Petroleum dated October 21, 1991, that the documented soil contamination at this site has been shown to impact the groundwater and will continue to do so unless remediated PHS/EHD, in the same letter, requested that a Corrective Action Plan for this site be submitted to PHS/EHD by January 15, 1992 PHS/EHD has not yet received a Corrective Action Plan for this site. It is essential to proceed with the cleanup efforts at this site in a timely manner, especially since the data has indicated the off-site migration of contaminants In these cases, the initiation of some form of hydraulic control over the migrating plume may be warranted Please submit a Corrective Action Plan to this office by October 5, 1992. A tnhston of San Joaquin CounryHcalth Care Scmccs /