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California Regional Water Quality Control Board h; <br />Central Valley. Region <br />Steven T. Butler, Chair <br />Winston H. Hickox Gray Davis <br />Secretaryfor Sacramento Main Office Governor <br />Environmental Internet Address: http://www.swrcb.ca.gov/—rwgcb5 <br />Protection 3443 Routier Road, Suite A, Sacramento, California 95827-3003 <br />Phone (916) 255-3000 • FAX (916) 255-3015 <br />13 November 2000 <br />Mr. Jim Lancaster <br />Woolsey Oil, Inc. <br />166 Frank West Circle <br />Stockton, CA 95206-4098 <br />REVIEW OF THE WORK PLAN ADDENDUM, WOOLSEY OIL COMPANY, SAN JOAQUIN <br />COUNTY <br />We have reviewed the 6 October 2000 Work Plan Addendum submitted by Ground Zero Analysis, Inc. <br />(GZA) on behalf of Woolsey Oil Company (Woolsey) for the bulk fuel plant at 930 Victor Road in Lodi. <br />The facility includes seven aboveground storage tanks (AGTs), associated appurtenances, an <br />office/warehouse building, and loading area. Historic petroleum hydrocarbon releases have <br />contaminated soil and groundwater at the site. <br />Our 11 September 2000 letter provided comments on the 28 August 2000 Work Plan for Additional <br />Subsurface Investigation. The addendum provides information on the geology and hydrogeology of the <br />region, but GZA states that detailed, site-specific information is not available. The addendum clarifies <br />that one deep boring will be drilled to collect and analyze up to 10 soil samples and up to five discrete <br />groundwater samples to determine the vertical extent of contamination. In our letter, we requested GZA <br />use conductor casing to minimize cross -contamination. However, GZA states that the current technique <br />will minimize the potential for cross -contamination. GZA may choose not to use conductor casing; <br />however, GZA needs to take appropriate measures to minimize the potential to introduce contaminants <br />further in the subsurface and deeper within the aquifer. <br />GZA proposes using EPA Method 8260 for fuel oxygenates, 1,2-dichloroethane, and 1,2-dibromoethane <br />analyses. This method is acceptable. Following collection of soil and groundwater samples, GZA will <br />abandon the borehole in accordance to San Joaquin County well abandonment standards. The original <br />work plan also proposes abandoning MW -1. <br />The work plan and addendum are hereby approved. By 27 November 2000, please provide a schedule <br />to implement the work plan, complete investigation activities, and submit a site assessment report. The <br />site assessment report needs to be in general accordance with the Items to be Included in a Site <br />Assessment Report. Also, we request you provide at least 72 hours notice prior to field activities, so staff <br />may be present, if practical. Based on the results of the investigation, additional assessment may be <br />necessary to delineate the extent contamination at the Site. <br />California Environmental Protection Agency <br />ca Recycled Paper <br />