SITE INFORMATION AND CORRESPONDENCE

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Ms. Margaret Lagorio• • November 30, 2001 placed. But we cannot make such predictions. As our October 11,2001 work plan states, five CPT borings are being advanced to a depth of 120 feet, if possible, in order to assess the vertical and lateral extent of contamination discovered in the previous phase of field work in CPT boring SB-11. This depth is nearly five times that of MW-1. The aspect of monitoring of both shallow and deep groundwater is separate and apart from the planned December field work, but it raises another important issue. On several previous occasions, Equiva has been required to continue to sample monitoring wells for constituents not found to be present, with the reasoning from PHS/EHD that numerous sampling events are required to establish trends. And while we disagree that non detections require trend analysis,we do agree that detections do. Therefore, even an appropriately placed monitoring well today will not necessarily yield definitive results sufficient for a complete PAR by the established due date. PHS/EHD has suggested in the past that progress at Shell sites in San Joaquin County has been slow. We would like to point out that progress at some site has been slow because of SJCPHS's slow responses. Here are some examples: • 4445 Pershing Ave, Stockton—Work Plan submitted September 25, 1997—no comment or approval of this work plan until our June 19,2001 meeting with PHS/EHD, • 880 Victor Road, Lodi—Work Plan submitted July 3,2000—No comment or approval until July 3, 2001, • 3011 Benjamin Holt Drive, Stockton—Site Investigation Report submitted March 2, 1999— No comments on report until February 27,2001. • 2575 Country Club Boulevard, Stockton—Corrective Action Plan submitted February 13, 1997—we have never received any written comment regarding this submittal. Despite the lack of response at the 2575 Country Club Boulevard site we have progressed in a proactive manner and installed a groundwater extraction system to provide migration control and mass removal of contaminants. It is also interesting to compare PHS/EHD's approach to 2575 Country Club versus the subject site, since at the subject site there are no identified sensitive receptors,and petroleum hydrocarbon concentrations in the groundwater are significantly lower. We would ask that PHS/EHD consider the relative risks at each of these sites and whether the strict schedule that has recently been imposed at the subject site is truly warranted. Based on the above and for the sake of completing adequate and appropriate characterization for the subject site case, we again ask for an extension for the PAR due date, at least for the three and a half months (March through mid-June, 2001) that we did not know that a deadline had been imposed. Barring any relief from PHS/EHD and in order to comply with your request, we 3