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Mill Creek Associates June 22, 1994 Water Resource and Environmental Consulting Joel Weiss Central Valley Regional Water Quality Control Board 3443 Routier Road Sacramento, CA 95827-3098 RE: Revised Site Characterization Workplan Roberts Petroleum Services/Woolsey Oil Co., Lodi, CA Dear Mr. Weiss, As requested by your office I am writing to present a revised workplan for completing the site characterization for the above referenced property. We have previously informed your office that recent data obtained from the site indicates that very likely all, or at least a significant portion, of the contamination did result from leakage from underground tanks. Attached is an analysis of a free phase product sample from well MW -8. This sample analysis indicates the product is a mixture of gasoline and kerosene. While gasoline has been stored in the above ground tanks, kerosene at the site was only stored in a 10, 000 gallon underground tank removed in 1988 or an existing 350 gallon underground tank. This discovery led to additional review of the file data concerning the removal of the underground tanks. Although the discrete tank excavation and line trench bottom soil samples were below action levels at the time the tanks were removed, a set of analyses for the soils removed during the tank pull (attached) show BTEX and TPH gas present at significant levels. Based upon these data it appears that releases have occurred from the existing or former underground tanks at the site and that this problem should be regulated as an underground tank case. We seek your concurrence in this regard and intend to submit a claim pursuant to S.B. 2004. Without regard to the source of the contamination we have prepared a plan for completing site characterization in anticipation of remedial action. As noted in your staff memo to Ms. Wendy Cohen of January 14, 1994, the contaminant extent in soil and groundwater at the site is well defined with the exception of the area east of wells MW -1 and MW -8. We propose to install a single monitoring well to a depth of approximately 15 feet below first encountered groundwater (estimated 60 +/- feet) at the location shown on the attached site plan. Soil samples will be collected at 5 foot intervals for logging and analytical purposes. A total of four soil samples will be submitted for laboratory analysis based on field screening (PID, discoloration, odors). Analysis will include BTEX, and Total Gasoline, Diesel and Kerosene hydrocarbons. Upon completion the well will be developed by surging and pumping W3 111911 -, Ce Box 120 a Vla"sfard, `'a. 96121 -j _+=3a. 9!6-2r-13-2"-!7 1 Fax 916-253-2294