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4 ' _ GEORGE DEUKMEJIAN,Governor <br /> CALIFORNIA REGIONAL <br /> WATER QUALF Y CONTROLBOARD— <br /> CINTRAL VALLEY REGION I <br /> 3443 ROUTIER ROAD <br /> SACRAMENTO,CA 95827-3098 �, ® 2 <br /> " ` <br /> A �r. ip <br /> q <br /> MAY 2 2 0817 <br /> ENVIRpMFNI AL H <br /> P EALTH <br /> 20 May 1987- ERMIT/SERVICES <br /> I <br /> Mr. Jim Thompson <br /> Kayo Oil Company 11 <br /> _„- P..O.. Box 190 <br /> Lodi , CA 95241 <br /> WORK PROPOSAL (AND SUBSEQUENT AMENDMENTS) BY J. H. KLEINFELDER AND ASSOCIATES FOR <br /> 800 EAST HIGHWAY 12 FAST GAS STAT1ION, LODI, CALIFORNIA <br /> I reviewed the 5 March 1987 proposal submitted by J. H. Kleinfelder and Associates <br /> for this site, and the additional information sent on 20 and 27 March 1987. To <br /> define the soil contamination the Kleinfelder report relies upon 1985 data; <br /> however, the vertical and lateral extent a soil contamination is undefined <br /> because there is little supporting sail data from any of the holes previously <br /> drilled. I reviewed our files and the only oil contamination data we have are <br /> odor and lover explosion limit (LEL) measuremerits from 11 of 18 monitor wells (MW) <br /> and one soil analysis from MW-7 ,aat 35 feet completed in 1985. This sample was <br /> apparently analyzed because of th'e strong odor and high LEL reading; however, the <br /> lab analysis shows no contamination. The lack of soil contamination data from <br /> most MWs, and the unreliable data:� on soil contiunination from the remaining MWs (as <br /> evidenced by the discrepancies in MW-7) indicates that basically we have no data <br /> for the degree of soil contamination at this site. <br /> To alleviate the situation Kle'infelder suggests drilling boreholes near the ' <br /> northwest and southwest corners 'of the tank pit and if soil odors are detected, { <br /> additional boreholes "will be drilled 10 feet urther away from the -assumed source <br /> of contami-nati-on"-; The line farmed by the pro osed boreholes, if contamination -is <br /> found, will define the extent ofIsoil contamiT ation only in those two directions. <br /> The additional information sent an 27 March 1S87 described the boring of up to 14 <br /> boreholes to define the extent of soil contamination. It appears that implement- <br /> ing this program may define thel extent of sc it contamination but your proposal <br /> still does not address the extent of ground water contamination. <br /> All monitor wells which encountered ground water have produced contaminated water <br /> samples which shows that the lateral extent of dissolved product contamination in <br /> ground water has not yet been determined . Also, as you stated in your 20 March <br /> 1987 status letter for this site, "The ground water monitoring well analytical <br /> data do not show a significant improvement in water quality." Because this <br /> makes it impossible to determine if the cone of depression created by your operat- <br /> ing recovery well is impacting a!11 contaminated water, and the extent and degree <br /> of soil contamination is undefined, we request that the recovery well be shut down <br /> I <br /> J <br /> f <br /> I� <br />