SITE INFORMATION AND CORRESPONDENCE

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Mr. Sheldon Heckman, c/o Ms. Karna E. Herrigfeld - 2 - 12 November 2002 Herum Crabtree Brown, Stockton • Preparing a corrective action plan (CAP). The Monitoring Report states that a site meeting with Regional Board staff has been requested to conduct a formal review of all pertinent geological and chemical data prior to finalization of the CAP. Comments: 1. In a letter dated 19 September 2002, Regional Board staff requested the following: 1) a Site Assessment Report by 15 September 2002 that included the results of the April 2002 soil and groundwater investigation, the SVE feasibility study, and recommendations for the Corrective Action Plan, and 2) a Corrective Action Plan (CAP) by 15 October 2002. On 10 October 2002, we received the Monitoring Well Installation Report(MWI Report), which included the April 2002 soil and groundwater investigation, but did not include the groundwater extraction/SVE feasibility study and recommendations for the Corrective Action Plan. The MWI Report recommended continued groundwater monitoring. The MWI Report did not include the information required in our 19 September letter. On 11 October, Regional Board staff received a phone call from AGE, requesting: 1) an extension on the CAP to 1 December 2002, and 2) a site meeting in early November 2002 to discuss a strategy for addressing the possible commingled leaking underground storage tank (UST) and Connell Motor Lift Truck spill groundwater plumes. AGE reported that VOCs, including 1,2-dichlorethane (1,2-DCA) from the spill site have been detected at the River City Petroleum UST site, which is also located on your property. AGE requested that all parties formulate a coordinated approach to remediation at both sites. AGE expressed concerns that the soil vapor extraction proposed for the spill site would adversely affect remediation at the UST site. We agreed to the CAP extension and meeting requests. As a result of the agreement, the decision to conduct the SVE feasibility study was postponed until after the November 2002 meeting. 2. The Monitoring Report analytical data method detection limits (MDLs) were inadequate for comparison to water quality objectives in several groundwater samples. Please work with the laboratory to achieve the MDLs equal to the lowest water quality numerical limits for applicable constituents of petroleum fuel components, as presented in the Regional Board memorandum provided as an attachment to our 19 September 2002 letter. 3. Additionally, duplicate sample results reported in previous monitoring reports were removed from the chronological data results tables in the current Monitoring Report. One of the removed duplicate sample results was the only detection of a contaminant. In future reports, please include all duplicate analytical data in the data tables.