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i Y Wt I April 29, 1988 Hartiing Lawson Associates PW 88-4924.03 Mr. Hal Miller The Southland Corporation Page 2 BACKGFOUND In October, 1986, the Southland Corporation (Southland) dis- covered that a 10,000-gallon fuel tank was leaking, and the tank was emptied. HLA performed an initial investigation to evaluate if water quality at the. perimeter of Southland's property had been affected by the leak. In our Phase I re- port dated February 10, 1987, we concluded that some petroleum hydrocarbons were present in the water at one mon- itoring well. In Phase II, an additional well was installed downgradient of that well and several additional borings were drilled and sampled to assess the distribution of hydrocarbons in the soil. The results from that investiga- i tion were presented in a report dated April_ 20, 1987. A Phase Ill investigation was implemented to evaluate yhe presence and extent of free product, and to develop remedial plans. Our proposal for this phase, dated December 3, 1987, was submitted to the San Joaquin Local Health District (SJLHD) for comment. We were informed that the SJLHD was no longer the lead agency in approving remedial efforts at the convenience store site, and that the CVRWQCB had now assumed that responsibility. The December. 3, 1987 proposal was then sent to the CVRWQCB, and in a telephone conversation between Mr. Gordon Boggs of :.he CVRWQCB and Mr. Stephen J. Osborne of HLN, Mr. Boggs indicated his approval After completing ,the field isivestigation and during report preparation, we received from the CVRWQCB a .description of the three reports. required before site remediation begins. ; - Because the results of the Phase III investigation indicated the presence of free product in several areas of the site, Southland and HLA agreed that source control measures should be implemented as soon as possible to minimize further migration of `petroleum-hydrocarbons. The Phase III report was issued to the CVRWQCB for review and Stephen comment. In a telephone conversation Frith Mr. 4' Osborne. of HLA,. Mr. Boggs. indicated that he believed imple- to be premature, with mentation of source control measures P , out full. definition of the horizontal extent of petroleum hydrocarbons. Mr. Boggs would not.schedule a meeting for HLA to present and discuss the findings of the Phase III report, nor anticipated remedial actions. We discussed.,the matter with you and agreed that .if. South- A. land .proceeded with source.control measures at this time, the CVRWQCB could decide .that such measures were not ode-