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• The tank pit samples TP1-B and TP2-B which were taken from soil immediately <br /> adjacent to the gasoline storage tanks showed very low concentrations of <br /> hydrocarbons, with one sample reported at 180 parts per million (PPM) and one <br /> sample showing non-detect. These soils were excavated and removed. <br /> • Side wall sample SW-9 which was taken approximately 4 feet east of the tank <br /> location, dropped to a concentration of 100 ppm. These soils were also <br /> removed. <br /> • Confirmation sample SW-11, which was taken approximately 8 feet east of the <br /> storage tanks, showed non-detect for gasoline. <br /> In addition, it should be known that the entire soil excavation project was overseen <br /> by a representative of San Joaquin County and a registered geologist who visually <br /> observed the sidewalls of the pit and took numerous readings With a photo ionization <br /> detector (PID) to confirm the completeness of the removal. The data and the <br /> observations made at the time of the tank removal strongly suggest that the actual <br /> source of the hydrocarbons release was not the tanks themselves, but the piping <br /> located at the western end of the northern tank, approximately 45 feet to the west <br /> of this sampling point. <br /> We believe that the technical data on this point is clear. There is no technical <br /> justification for requiring further soil investigation on the "vacant lot." It was both <br /> logical and appropriate for San Joaquin County to grant closure for the soil <br /> remediation of this site. <br /> Regarding the 1990 tank removal project, your understanding of that project is in <br /> error. That removal activity dealt only with the removal of the station's 550-gallon <br /> waste oil tank which was used specifically for the temporary storage of used <br /> automotive drain oil. At the time that tank was removed, approximately 60 cubic <br /> yards of soil were overexcavated from the tank pit. Soil samples taken at that time <br /> showed concentrations of total hydrocarbons in a range up to 270 ppm. The 1,370 <br /> gallons of "free product contaminated groundwater" to which Ms. Deutsch refers, <br /> were pumped out during the removal of the gasoline storage tanks. The actual "free <br /> product" was more accurately described as a "partial sheen" on the water. <br /> Regarding the residual soil concentration left behind in 1990, please note that the <br /> entire area was removed during the overexcavation of the main tank pit done in 1992. <br /> Thus, the soils characterized by these residual concentrations are no longer on the <br /> property. <br /> 2. Concernsrelated to groundwater flow direction. Ms Deutsch's concern relates <br /> to the possibility that seasonal variation in groundwater flow direction might cause <br /> contaminated groundwater, if it were present, to flow in a northeasterly direction <br /> beneath the vacant lot. <br />