SITE INFORMATION AND CORRESPONDENCE

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Pe Memo From the Desk of Mary Meays Senior REHS To: David Irey, SJC Deputy District Attorney Date: October 29, 1996 Subject: 2905 Benjamin Holt Drive David, I am forwarding you the following information which we have discussed: 1) Chevron correspondence dated October 28, 1996. 2) PHS/EHD correspondence dated November 30, 1995 commenting on the August 31, 1995 Work Plan submitted for the Chevron facility. 3) PHS/EHD correspondence dated December 26, 1995 which summarized the December 8, 1995 meeting held with Chevron to discuss cleanup goals and compliance scheduling. 4) City of Stockton Memo from Ed Formosa dated October 24, 1996. I have discussed with Beth Thayer with the Central Valley Regional Water Quality Control Board the contents of Chevron's correspondence dated October 24, 1996 and the following concerns were expressed: 1) The water quality goals which Chevron is again proposing have specifically been disapproved because their proposed goals fail to conform with UST Regulations or the CVRWQCB Basin Plan. The methodology to achieve acceptable goals for site closure may be modified once "active remediation" has reached the end of its effectiveness for site conditions. 2) The start-up of the remediation system by November 29, 1996 does not ensure that the system will remain in operation. Standard language should have been included that indicated that the system would operate continuously except for scheduled maintenance and that the SJVUAPCD permit to operate would be obtained once startup data was obtained. 4) Chevron misrepresented their level of remedial effort since only one soil sample was obtained at 16.5 feet following very limited over-excavation. The other five soil samples collected from the tank pit were collected at 14 feet. 5) Chevron's efforts to inquire about the status of the City of Stockton's wells were less than thorough. The City of Stockton Deputy Director of the Municipal Utilities clearly indicated that the purpose of both wells is to provide domestic water supply. PHS/EHD has repeated requested that Chevron provide a sampling plan for the regular monitoring of these wells and which has never been provided. 6) Given that Chevron initially submitted the Work Plan of August 1995 as a corrective action plan, the time frame which Chevron has proposed for a corrective action plan submittal is extremely generous and which reasonably could be accomplished by March 30, 1996. We will need to discuss a mutually agreeable regulatory response. Thank you.