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Shell Oil Products USA~ <br /> Former Station, 1267Country Club Blvd, Stockton. <br /> Page 2 of 2 <br /> • As Shell continues to use "cost-effectiveness" as an argument for NOT complying <br /> with EHD's directives and advise, EHD now advises that reimbursement for costs to <br /> remobilize to repeat the investigation that was previously directed by EHD, may not <br /> be reimbursed by the Clean Up Fund. <br /> • EHD reiterates its conclusion that the assessment of the waste oil UST is not <br /> complete and again directs Shell to further investigate and define the lateral and <br /> vertical extents of the waste oil UST release. <br /> EHD approves Shells `phased' approach, as stated in the Letter/Work Plan, as this appears <br /> all Shell will offer and further discussion will only cause further delay of this investigation. <br /> EHD believes that it would be more cost effective to maximize the use of the mobilization <br /> and address all intervals of concern rather than to lose time and have to mobilize again at a <br /> later date; especially since no cognitive argument has been offered to show the data from <br /> the deeper intervals is not reliable. <br /> EHD considers four consecutive quarters of monitoring as adequate to form conclusions <br /> based on the ground water data. If petroleum contaminants are present after this time <br /> period, Shell is hereby directed to submit a work plan within 30-days for deeper <br /> screened monitoring well installations. <br /> In the interest of cost-effectiveness, EHD offers the following recommendation. Since <br /> Shell will be mobilizing onsite for the gasoline/diesel UST monitoring well installation <br /> ("S-7"), the required/directed waste oil UST investigation could be conducted at the same <br /> time. Shell's proposal to place S-7 (monitoring well) as shown in the Letter/Work Plan, <br /> does not provide for assessing the down gradient area of the former waste oil UST as <br /> required by EHD. EHD recommends Shell submit an addendum that provides for the <br /> placement of an additional boring/well north/northeast of former waste oil UST area, near <br /> former CPT-6. <br /> EHD has received notification from the State Water Resources Control Board (SWRCB) <br /> Clean Up Fund (CUF) that this site has recently (May 5, 2004) become eligible to receive <br /> reimbursement. Once the compliance review has been successfully completed, this site <br /> could be added to the priority list for reimbursement. EHD cautions that continued failure <br /> to comply with directives can jeopardize your ability to become and/or remain eligible to <br /> receive cost reimbursement and may result in formal actions. <br /> Questions and response letters may be addressed to Michael Infurna or you may contact <br /> me at (209) 468-3454. <br /> Donna Heran, RENS, Director <br /> Environmental Health Dep ment <br /> Michael J. Infurna Jr., Senior REHS Nuel C. Henderson Jr., RG <br /> LOP / Site Mitigation Unit IV LOP / Site Mitigation Unit IV <br /> MI/ <br /> c: CVRWQCB — James Barton, Sacramento. <br /> c: Cambria — Joe Neely, PO Box 259, Sonoma, CA., 95476. <br /> c: SWRCB-CUF — Claim #018070 - Barbara Rempel, Sacramento <br />