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1.0 INTRODUCTION 1.1 Background Information The project site is located at 3931 Newton Road, in an industrial area on the northeast o Askirts of Stockton near U. S Highway 99. The location of the site is shown in Figure 1, and the sits facilities are shown in Figure 2 Originally agricultural property, the site was developed as a a,mmercial truck terminal in 1973 The property occupies an area of about 3 5 acres Topography in the area is generally flat, although the project site is elevated several feet above the adjacent parcels There is a maintenance building and office frontmg Newton Road, wi ib a large, unpaved storage yard/parking lot in the rear A diesel and gasoline fueling facility, consist ng of two underground storage tanks (UST's), was formerly present on the east side of the storage yard (Figure 2) This facility was removed in 1989 and replaced with an above-ground fueln g facility, which is located to the west of the abandoned facility Upgradient Environmental Consultants (Upgradient) assumed the responsibility for asses-,meat and monitoring of groundwater contamination at the facility in September, 1994 In November 1996, Upgradient submitted a Problem Assessment Report, which was approved by San Joaqu in County Public Health Services, Environmental Health Division (PHS/EHD) in January 1997 11'HS/EHD recommended that a Corrective Action Plan be submitted outlining the assessment, press tinting the results of a feasibility study of potential remediation methods, and discussing applicab a cleanup . goals For various reasons, the project stalled at this point and no Corrective Action Plan was prepared Groundwater monitoring continued sporadically through early 1998, but due to high water levels in the monitor wells, no samples have been collected since November 1997 1.2 Regulatory Concerns In September 1998, representatives of PHS/EHD met with the owners of Gillies T1 ticking to present their concerns about the extent of contamination at the site and discuss the fur ire of the investigation in a written summary of this meeting, PHS/EHD informed Gillies Truckm; that two additional monitor wells, a potential receptor survey, and a fate-and-transport model are needed to complete the investigation PHS/EHD directed that one of the monitor wells be coml,leted at a shallow depth to investigate groundwater conditions above the screened interval in th_- existing wells, and that the other well be completed at a depth sufficient to determine whether soil contamination exists at the historically lowest static water level (124 feet) in the site area Citing the data collected in earlier phases of drilling, Upgradient disagreed with I'HS/EHD regarding the vertical extent of contamination and requested that PHS/EHD re-ex,anme the Problem Assessment Report Upgradient also contacted the State UST Cleanup Fund to discuss the procedures for appealing the PHS/EHD request for deeper drilling The UST Fund sul isequently responded to this request in January 1999 and instructed Upgradient to submit a Cost Pre-Approval Request to prepare a Work Plan to meet the PHS/EHD directive Upgradient submitted the Request on January 19, 1999 and the UST Fund approved it on February 19, but informed Upgr tdient that 1