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EDWARD C RALSTON UNOCAL CORPORATION 2000 CROW CANYON PLACE SUITE 400 SAN RAMON CA 94583 RE: UNOCAL STATION #5886 2701 MARCH LANE STOCKTON CA SITE CODE: 1176 On July 27, 1995 and subsequent days thereafter, violations of Corrective Action Regulation occurred at the above referenced site. Violations include, but, are not limited to failure to provide notification to local regulatory authorities regarding soil and or potential groundwater petroleum hydrocarbon contamination, and interim remediation in the form of overexcavation and subsequent disposal without prior submittal of a corrective action plan (workplan). As a result, administrative/enforcement action is pending. On August 15, 1995 an administrative office hearing took place at the offices of San Joaquin County Public Health Services Environmental Health Division (PHS-EHD). As of August 15, 1995 Unocal corporation had not fulfilled its obligation to submit the required workplan and report, at that time PHS-EHD again directed Unocal to comply with all regulations pertaining to this site. Petroleum Hydrocarbon contaminants have been identified and confirmed by laboratory analysis of the soil at this site and as a result this site has been entered into the Local Oversight Program (LOP) and PHS-EHD Contaminated Site Database. A review of the Corrective Action Plan submitted August 18, 1995 by Delta Environmental Consultants, Inc. to PHS/EHD has recently been reviewed and we provide the following comments: 1. All work proposed related to assessment and remediation must be pre -approved by PHS- EHD. All work related to assessment and remediation at this site must be witnessed by PHS-EHD Site Mitigation Staff. Call a minimum 48 hours in advance of proposed work to arrange for site inspections. v 2. Although removal of crushed rock is proposed, the workplan submitted fails to accurately address the actual extent or size of overexcavation which have been documented at this site. This information is critical to site assessment, characterization and remediation due �"t to the crushed rock backfill placed in these excavations which may interfere in assessment and remediation activities. In addition, crushed rock may also act as a direct conduit to v groundwater which may potentially further impact this site. Please provide as -built drawings to scale indicating the size and locations of all known excavation including volumes of crushed rock placed in any excavations on site. All crushed rock must be removed prior to or concurrent with site assessment.