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A M B R A Mr Michael Infurna
<br /> April 6, 2005
<br /> RESPONSE TO SJCEHD LETTER
<br /> Waste Oil Investigations
<br /> In correspondence dated October 11, 1996, San Joaquin County Public Health Services,
<br /> Environmental Health Division (SJCPHS/EHD) requested that Shell perform a soil and
<br /> groundwater investigation in the vicinity of the former waste oil tank Specifically, SJCPHS/EHD
<br /> requested that Shell analyze soil samples for cadmium, chromium, lead, nickel, zinc, oil and grease,
<br /> chlorinated hydrocarbons, polychlorinated biphenyls (PCBs), pentachlorophenol (PCP),
<br /> polynuclear aromatics (PNAs), and creosote SJCPHS/EHD further requested that these
<br /> constituents also be analyzed in groundwater, if detected in soil
<br /> During the April 1997 site investigation, Enviros drilled a soil boring (SB-2) in the vicinity of the
<br /> former waste oil tank In accordance with Enviros' December 23, 1996 Site Investigation Work
<br /> 1 Plan, which was approved by SJCPHS/EHD on December 30, 1996, soil and groundwater
<br /> samples from this boring were analyzed for cadmium, chromium, lead, inekel, zinc, oil and grease,
<br /> r HVOCs (which include chlorinated hydrocarbons), and SVOCs (which include PCF and PNAs)
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<br /> . Note that PCB and creosote analyses were not conducted The soil samples from SB-2 contained
<br /> detectable concentrations of chromium, lead, nickel, zinc, and oil and grease No chlorinated
<br /> `a hydrocarbons, PNAs, or PCP were detected in soil The groundwater sample from SB-2 contained
<br /> detectable concentrations of clirornium, nickel, zinc, and naphthalene No chlorinated
<br /> hydrocarbons, PNAs other than naphthalene, or PCP were detected in groundwater
<br /> In their September 20, 2002 letter, SJCEHD requested additional analyses for waste oil
<br /> constituents and submittal of a work plan In the November 19, 2002 Response Letter/Sate
<br /> Conceptual ModellSite InveAttgation Work Plan, Cambria proposed analyzing groundwater
<br /> samples from well S-3, located approximately 20 feet from the former waste oil tank, for
<br /> naphthalene, PCBs, and creosote to complete the waste oil investigation at the site
<br /> SJCEHD's January 8, 2003 letter, which approved the November 19, 2002 work plan, states that
<br /> "EHD agrees with Shell's conclusions regarding additional analyses for the waste oil UST
<br /> constituents with the exception of those regarding the metals " The letter requested that
<br /> groundwater samples from "the waste oil UST area" also be analyzed for dissolved metals
<br /> (cadmium, chromium, lead, nickel, and zinc) as some previous samples exceeded maximuin
<br /> contaminant levels (MCLS)
<br /> . Therefore, groundwater samples from well S-3 were analyzed for naphthalene, PCBs, creosote,
<br /> and dissolved metals for two quarters (second and third quarters 2003) No cadmium, chromium,
<br /> lead, naphthalene, creosote, or PCBs were detected Nickel and zinc were detected up to 9 1 and
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