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California <br />Regional Water Quality Control Board <br />Winston H. Hickox <br />Secretaryfor <br />Environmental <br />Protection <br />11 September 2000 <br />Central Valley Region <br />Steven T. Butler, Chair <br />Sacramento Main Office <br />Internet Address: http://www.swrcb.ca.gov/—rwgcb5 C-1 <br />3443 Routier Road, Suite A, Sacramento, California 95827-3003 c�10 <br />Phone (916) 255-3000 • FAX (916) 255-3015 rr <br />Mr. Jim Lancaster N <br />Woolsey Oil, Inc. <br />166 Frank West Circle <br />Stockton, CA 95206-4098 <br />REVIEW OF THE WORK PLAN, WOOLSEY OIL COMPANY (FORMER ROBERTS <br />PETROLEUM), SAN JOAQUIN COUNTY <br />Gray Davis <br />Governor <br />I have reviewed the 28 August 2000 Work Plan for Additional Subsurface Investigation (Work Plan) and <br />the 18 July Letter responding to my 30 June letter. Ground Zero Analysis, Inc. (GZA) submitted the <br />Work Plan and Letter on behalf of Woolsey Oil Company (Woolsey) for the bulk fuel plant at 930 <br />Victor Road in Lodi. The facility includes seven aboveground storage tanks (AGTs), associated <br />appurtenances, an office/warehouse building, and loading area. Historic petroleum hydrocarbon releases <br />have contaminated soil and groundwater at the site. <br />Our 30 June letter requested preparation of a work plan to delineate the lateral and vertical extent of <br />contamination at the site. In an 8 August phone conversation with Mr. Gregory Stahl of GZA, he stated <br />that the initial location of MW -10 was further north at SB -10. However, petroleum contaminated soil <br />and groundwater were encountered. GZA advanced another boring (SB -11) further south and <br />presumably downgradient of SB -10. Mr. Stahl stated that groundwater directly beneath the site <br />consistently exhibits a southeasterly trend, when contoured without MW -10 data. A crossgradient <br />component occurs near MW -10, skewing the groundwater contours south. Therefore, Mr. Stahl stated <br />that MW -10 is downgradient of the site, and further delineation is unnecessary. In consideration of this <br />information, this is acceptable, unless concentrations in MW -3, MW -5, or MW -6 increase or the <br />groundwater flow direction changes, which will necessitate an additional investigation. Also, remedial <br />systems will be required to capture groundwater out to MW -10 to ensure full capture and removal of <br />groundwater contaminants. <br />The Work Plan outlines field activities to delineate the vertical extent of contamination beneath the site <br />and abandon well MW -1. GZA proposes to advance one boring using a hollow stem drill rig to <br />approximately 100 feet below ground surface. The Work Plan does not provide any specific <br />hydrogeologic information, so staff cannot evaluate whether the proposed location and depth are <br />appropriate. The deep boring is proposed south of MW -8 and north of MW -3 and MW -6. The Work <br />Plan proposes to collect up to 10 soil samples and one groundwater sample from the lower aquifer for <br />laboratory analysis, including the following analytes and methods: <br />California Environmental Protection Agency <br />va Recycled Paper <br />