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Despite previous contacts and discussion permits for the tank removal were filed with the SJCFPB on March 8, 1996 and a new UST permit application form was submitted to PHS-EHD on March 11, 1996. The permits were granted on March 11, 1996 and March 12, 1996 respectively (see Appendix B). During conversations on March 14, 1996 with Mr.Steve Dalton of SJCFPB and Mr. Eric Trevena of PHS-EHD, both of whom were unavailable on March 15, 1996, the date scheduled for tank disposal, they indicated that their presence was not required for tank removal and off-site disposal. However, sampling activities required observation by PHS-EHD and would require scheduling for a later date unless a substitute for Mr. Trevena from PHS-EHD contacted Wright before March 15, 1996. On March 15, 1996 the tank was unwrapped by Wright personnel, observed to be free of any liquid, was dry on the interior and there were no apparent odors. Surface debris (dirt and sand) was removed from the exterior of the tank. A GasTech meter was used to measure the tank internal atmosphere for oxygen, lower explosive limit (LEL) and volatile organic compounds (VOC) in parts per million (PPM); the readings were 21.5% oxygen, 0% LEL and zero ppm VOC. The tank exhibited no hazardous characteristics. Nonetheless, the tank was inerted with 17.83 pounds of dry ice on the basis of 30 pounds per 1000-gallon tank capacity as required by the permit issued by PHS-EHD. Samples of the tank and vent piping were collected and retained by Wright. The remainder of the tank and piping was then lifted onto a truck for shipment to Triangle of Sacramento in Sacramento, California for disposal/recycling. The tank disposition tracking record and disposal certification is presented in Appendix C. While removing the tank and piping from the site it was observed that the excavation contained significantly more water than observed on December 13, 1995 during the site visit and when the workplan was submitted. A revision to the workplan was discussed with Ms. Turkatte and confirmed by letter on March 25, 1996. The revision was approved over the phone by Ms.Turkatte. SAMPLING - TECHNICAL RATIONALE The PHS-EHD indicated that soil samples would be required from the former tank pit. The PHS-EHD also indicated that a "third party" sampling would be required by their office in that a Wright representative could not transport the sample to the analytical laboratory. The soil sampling was performed under the current Wright sampling protocol, a summary of which is presented below. The excavation had flooded by the time the permits were issued and agency review of the sampling workplan had been completed. As a result of discussions in the field with Mr. Trevena and Ms. Linda Turkatte of PHS-EHD, it was decided to modify the sample locations and eliminate the analysis for volatile organics as specified in Ms. Turkatte's letter of January 8, 1996. Two water samples would be collected from the excavation prior to collecting soil samples, which was anticipated to stir up sediment. The sidewall samples (perimeter) would be collected at the capillary fringe. Four samples from the soil excavation stockpile would also be collected using the same protocol. The samples were collected at the locations as shown on Figure 3, attached. SAMPLING - SOIL FIELD METHODS The soil samples were collected from the specified locations in the former tank pit or the stockpile using the following procedure with the included changes from the usual Wright Protocol. Wright supplied the tools, sampling materials and physical help to the "third party." The soil samples were collected by Wright personnel using a hand held auger at the PHS-EHD specified locations. The sample was removed and pressed into a clean brass liner, until it was completely filled, by the "third party" who was a representative of Priority