SITE INFORMATION AND CORRESPONDENCE FILE 1

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Scott T Hooton page 2 In three separate letters from PHS-EHD, starting on April 14, 1994, an updated site map has been requested that identifies the many traffic boxes that exist on the site that contain PVC casings of unknown purpose. On October 31, 1995, PHS-EHD staff forwarded a map of the site with all of the boxes identified as "UNKNOWN" to you and requested clarification. In this letter PHS-EHD directed you to again include an updated site map and identify all of the boxes and include this data in the Fourth Quarter Monitoring Report, 1995. After review of the Fourth Quarter Monitoring Report for 1995, received late in February 1996, PHS-EHD, in a letter dated March 11, 1996, noted that the updated site map was not included, MW-5 sample data was deleted, and again, no conclusions or recommendations, as previously directed, were included in the quarterly monitoring report. In preparation for closure, consecutive and complete quarterly monitoring reports are required by PHS- EHD. All monitoring wells are to be sampled and analyzed for all constituents of concern and reported at acceptable detection levels. Reports not meeting the minimum requirements will not be accepted by PHS-EHD. Sites preparing for closure should provide sufficient time to allow submittal, review and acceptance of the reports by PHS-EHD prior to the next consecutive monitoring date. The time schedule required in the PHS-EHD March 11, 1996 letter still needs to be submitted. The schedule you plan for sampling the site's wells and submit the report must allow time for PHS-EHD's review before the next monitoring event. In addition, PHS-EHD has concerns with the vapor extraction testing done in 1992. The report of the test indicated that"the hydrocarbon concentration in the extracted soil gas was substantial" and "the volume of soil gas extracted under vacuum appears to be higher than expected.........". PHS-EHD is not aware of any further vapor extraction work on site and is concerned with the level of contamination that may still exist in the soil. Included in your Closure Report should be explanations for why the vapor extraction system was not placed online and data should be included that addresses the current status of the soil. High levels of MTBE (2,700 ug/I pre-purge and 4,100 ug/I post-purge) exist in the groundwater at MW-6, just up-gradient of the existing underground tanks, and PHS-EHD is concerned that this may be a newly developing problem. Conclusions and remarks in the next quarterly monitoring report should address this concern. Without a clear understanding of the site and a complete picture of the investigative efforts made to date, PHS-EHD cannot evaluate this site for closure. Finally, your concerns for the copy of the previous letter to the San Joaquin County Deputy District Attorney can be attributed to your failure to comply with requests and directives issued by PHS-EHD in the past. All directives, documents, or requests from PHS-EHD are to be complied with or the site is considered to be in non-compliance. After years of continuing requests for documents that have not been included in the minimum requirements, PHS-EHD feels that it has been more than lenient in its actions of the past_ Now that a closure request is pending, stricter guidelines must be maintained in order to meet the minimum standards under the regulations. Current PHS-EHD policy requires that preparations for formal actions be copied to the DA so that an enforcement action file can be started in the event it is needed in the future.