SITE INFORMATION AND CORRESPONDENCE

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Appendix B guidelines without identifying specific items missing from the Closure Evaluation Report required by the SJCPHS. Since a copy of the Appendix B guidelines were included in Appendix A of the Closure Evaluation Report, it is somewhat confusing why the SJCPHS sent a copy of the Appendix B guidelines to Ultramar. RTD concludes that the deficiencies in the Closure Evaluation Report are contained in the narrative of the February 24, 1995 SJCPHS letter to Ultramar. RTD has summarized the SJCPHS comments and our response below: 1. Indicated the Closure Evaluation Report did not specify that the recommendations made were in conformity with CCR, Title 23, Division 3, Chapter 16, Article 11 which outlines the requirements of corrective action. 2. Determined that conditions were present to require soil and groundwater investigation to determine a cost-effective method of cleanup. 3. Indicated that the Closure Evaluation Report failed to provide adequate assessment of the potential effects that residual contamination may have on groundwater and a feasibility study to evaluate alternatives for remediation of the actual or potential adverse effects of the unauthorized release. 4. Indicated that nuisance has been demonstrated during tank removal along with subsequent excavation. 5. Indicated that significant contamination in the form of petroleum hydrocarbon pollution continues to act as a nuisance to the people of San Joaquin County. Based on the numerous technical comments outlined above, RTD will respond to each of the enumerated comments in turn: 1. The recommendations contained in the Closure Evaluation Report are in conformity with Article 11 in respect to completion of the scope of corrective action. Corrective action, as defined in Article 11, includes one or more (not necessarily all) of the following phases: (1) Preliminary Site Assessment Phase (2) Soil and Water Investigation Phase; (3) Corrective Action Plan Implementation Phase; and (4) Verification Monitoring Phase. Ultramar has completed phase (1), phase (2), and phase (3) of the corrective action scope. One conclusion of the Closure Evaluation Report was that the preparation and implementation of a Corrective Action Plan is unnecessary. RTD concurs with this conclusion. 2. Based on RTDs review of the previous work conducted at the subject site under the direction of, and stamped by appropriately licensed professionals, we conclude that the vertical and horizontal distribution of petroleum hydrocarbon impacts to soil were adequately characterized prior to and during UST removal and excavation activities. Since petroleum hydrocarbon concentrations in groundwater have been near or below detection for the entire period of record, the extent of impacts to groundwater from the on-site release has been adequately characterized as well. Based on the professional opinion of RTDs Registered Geologist, sufficient soil and groundwater investigations have been conducted_ In addition, SJCPHS indicated that the soil investigation conducted in - 3 -