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INTE* NAL MEMORANDUM <br /> . f <br /> i <br /> � f <br /> �i <br /> T O: James B. Maughan, F R O M: Gordon Lee Bogg6 f' <br /> Laura Scudder, Tracy File <br /> D AT E: 28 February 1991 SIGNATURE: <br /> F <br /> SUBJECT: CONCURRENCE <br /> CLOSURE BY THE SAN OAQUIN COUNTY UBIEALTH SERVICES <br /> I reviewed the Laura Scudder file and reports submitted to support the property <br /> owners' request for concurrence with the San Joaquin County closure for this site. <br /> There are several discrepancies in the drilling, investigation, sampling and analysis <br /> which are to be clarified before we can consider the site for closure. I have transmitted <br /> our concerns to Laurie Cotulla at County Health. <br /> There are two unauthorized leak reports in the file: 8 February 1988, a tank leak for <br /> "Total Extractable Volatile Hydrocarbons" (possibly diesel?); and 15 August 1989, a <br /> "leaded gasoline" tank leak. The site map in the 5 June 1990 Weston Engineering <br /> report shows the tanks are separated by 270 feet. <br /> Following are my comments: <br /> 1. There is no indication where soil samples were taken in the tank pits <br /> <i and along the piping which was removed. <br /> 2. Soil sampling depths and number are not shown. <br /> 3. The results of the required multiple soil tests are not in the report. <br /> 4. A monitoring well was drilled and placed in the diesel tank excavation, <br /> but none in the gasoline tank leak area. The well was last sampled on 2 <br /> May 1990; it should be sampled and analyzed again. <br /> 5. No ground water gradients are provided. <br /> 6. There is a water tower 90 feet from the leaking gasoline tank but no <br /> indication of on- site or nearby water wells was provided. <br /> 7. Soil samples are to be analyzed for total lead by EPA Method 7421. <br /> 8. No well logs showing subsurface conditions were submitted. <br /> 9. The report contains no pagination; however, item 6.0 of the report states <br /> that the Tri - Regional Recommendations were used to show compliance <br /> with the detection limits. The Tri - Regional Recommendations is a <br /> comprehensive document for assessing problems at sites. It is not used <br />