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11 September 1996 AGE Project.No. 95-0108 ' Page 2 of 10 alluvial and floodplain sheet deposits.(predominantly sand;silt and clay) of Quaternary age, which ' is derived from.the Sierra Nevada Mountains.Beneath-the upper sedimentary deposits lies a thick- sequence of marine deposits of Mesozoic age, which in turn is underlain by a pre-Jurassic complex of igneous and metamorphic rock. ' 2.4. UNDERGROUND STORAGE TANK REMOVAL, On 20 December 1991,the three USTs were removed from the site by Claude C. Wood,Co:of Lodi, t. California. Underground Tank Closure/Abandonment Inspection.reports on file with the PHS-EHD ; indicate that all tanks-andpiping were in poor conditions upon removal. Approximately,350.cubic yards of excavated soil was stockpiled adjacent to the UST excavation: Surface water had collected ., in the excavation during the UST removal: After removal of the USTs, FGL Environmental of Stockton, California, collected soil and grab ,. water samples from thesite: four soil samples were collected from stockpiled soil; one grab water sample was collected from,the excavation. Total petroleum. hydrocarbons quantified as diesel (TPH-d) weredetected in the stockpile soil samples at concentrations up to 1,460 parts per million (ppm, reported as milligrams per kilograrn) ; toluene,ethyl benzene and total xylenes were detected at concentrations of 0.07 ppm;0.52 ppm and 1 3 ppm, respectively. Benzene was'not detected in the soil samples. ,TPH-d 'and xylenes were detected in the grab'water sample at concentrations of 10,300 ppm and 0.63 ppm, respectively. ' Analvtical results are summarized on Table 1. Copies of the laboratory report are included,.in 'Appendix A. 2.5. APPLICATION OF BACTERIAL INOCULUM On 03 March 1992, Mr: Eric Trevena, of the PHS-EHD observed-that remedial action was being performed at the site without the authority of the local regulatory agency. The'former UST excavation had been filled with water and a bacterial inoculum placed into the excavation. The intent of the procedure was to inoculate the soil surrounding the former UST excavation with hydrocarbon- degrading bacteria to remediate the soil. A Notice To Abate, dated 03 March 1992, issued to Mr. Les Calkins from the PHS-EHD, indicated ; that Section 2722(b)of the California Underground Storage,Tarik Regulations states that prior to any ; ' corrective action at a UST site, the responsible.party shall notify the.regulatory agency of the proposed remedial action and comply with any requirements that the regulatory agency sets. The PHS-EHD directed that any unauthorized remedial action be ceased immediately. The PHS-EHD