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22=52- IFm FROM gLnMO TO 12094640138 P.02 <br /> n 0 <br /> WELLS FARGO RA.Nws COMMENTS TO <br /> UNOCA.U'S WORK PLAN <br /> 1034 CENTRAL AVENUE <br /> TRACY, CALIFORNIA <br /> e following comments pertain to the subject work plan which was prepared by Pacific <br /> nvironmental Group (PEG), on behalf of UNOCAL, dated October 6, 1994. Wells Fargo <br /> ank (WFB)received a copy of the plan on October 17, 1994. The work plan as proposed <br /> i not acceptable. UNOCAL must revise the work plan to address the following issues as <br /> minimum t6 the satisfaction of the San.Joaquin County Environmental Health Department <br /> ( CEHD) aid WFB. <br /> Laeati n a n e oval of Former USTs. UNOCAL must demonstrate that the former <br /> nderg7roun.d'storage tanks (USTs) do not remain on the property. PEG was completely <br /> s lent on this issue. There are apparently two separate clusters ()f three (3) USTs previously <br /> i stalled and ppperated on the property at different times according to historical,information <br /> rovided by LTNOCAL to PEO. 'there has been no dommentation from UNOCAL to <br /> confirm that'the USTs have been removed. As such, if they still remain they could pose a <br /> sk to the public and the environmental. <br /> erefore, UNOCAL must conduct ground pcnetrating radar(GPR)surveys to confirm the <br /> re,sence or absence of the USTs, followed by trenching near the presumed location of the <br /> former USTs. (Note: The magnectic survey performed by Levi Swift for WFB is not <br /> sufficient or technically adequate to confirm the absence of the USTs. Further, WFB has <br /> burden toi confirm the absenee of the UST,-.). The trenching can be shallow since most <br /> STs are covered with about three (3) feet of fill. The intent is to uncover any avidence <br /> o the prese4ce of the tanks in the areas either suspected or identified by UNOCAL}s <br /> h. I <br /> storical data or on the basis of the GPR results. Any future property owner will require <br /> t at the tanks are removed, and if the USTs remain, the USTs must be removed by <br /> VOCAL, at their cost according to prevailing federal, state and local laws, regulations, <br /> ordinances and codes. The removals must be documented to SJOBUD and WFB. i <br /> 2 Historical_Qlaati on. P03 references a UNOCAL 1435 general arrangement plan that <br /> d cuments key features and the layout of buildings and ancillary devices including the USTs <br /> a this pwropeirty. UNOCAL must provide S.TCEHD and WFB with this general arrangement <br /> ori, and all pertinent information regarding their ownership and operation of this gasoline <br /> sl ation at the property pertaining bulk storage of hazard substances and releases of <br /> hazardous substances at a minimum. <br /> 3 Location of Borings. PEG elected to locate boring, U-E,in the southwest corner of the <br /> parking lot as shown.on Figure 2 of their work plan. Considering that Levi Swift reported � <br /> si ibsurface contamination from his goring, B-4, PEG should also place a boring in this area. <br /> -2- <br />