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Work Plan Comment page 2 <br /> Shell Station (former), 1267 Country Club <br /> Stockton <br /> • EHD provisionally accepts Shell's decision not to further investigate <br /> the fuel oxygenate contaminants on the site as the USTs were <br /> removed in 1974 but reserves the right to require further <br /> characterization of such contaminants if future research indicates a <br /> likelihood that Shell's use of the site contributed to the problem; and <br /> • EHD agrees with Shell's conclusions regarding additional analyses <br /> for the waste oil UST constituents with the exception of those <br /> regarding the metals. The concentrations of cadmium, chromium, <br /> lead, nickel, and zinc in soil are within the range of normal <br /> background concentrations for California soils and are not of <br /> concern; however, the results from the ground water sample are <br /> open to question. The detection limits for cadmium and lead <br /> exceeded each metal's MCL and therefore the metals cannot be <br /> discounted as concerns. The concentrations of nickel and <br /> chromium actually exceeded MCLs as the laboratory report gives the <br /> concentrations in milligrams per liter, not parts per billion as <br /> reported in the text of the 10 July 1997 report. These concentrations <br /> may represent total metals in the water sample rather than dissolved <br /> metals. A ground water sample from the waste oil UST area should <br /> be properly collected and preserved for analysis for the dissolved <br /> metals of concern to resolve this issue. EHD also requests that the <br /> sample also be analyzed for naphthalene to verify the initial result. <br /> REASONS FOR DISAPPROVAL OF THE WORKPLAN (H&S Section <br /> 25299.37(c)(3)1: <br /> • None. <br /> /- �- <br /> DATED: D3 BY <br /> -Z44 <br /> Michael Infurna, REH (20),ff68-3454 <br /> Nuel Henderson, RG. (209) 468-3436 <br /> c: CVRWQCB - James Barton, Sacramento. <br /> c: SWRCB-CUF - Mark Owens, Sacramento. <br /> c: Cambria - Joe Neely, PO Box 259, Sonoma 95476. <br /> [X] faxed to consultant on: 0 <br />