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i • C A M B R A Mr Michael Infurna Apnl 6, 2005 • 195 ppb, respectively, these concentrations are below the MCL.s for these constituents (100 and 5,000 ppb, respectively) Cambria reported these results in our July 24, 2003 Groundwater Monitoring Report — Second Quarter 2003 and December 4, 2003 Groundwater Monitoring Report—Third Quarter 2003 In March 22, 2004 correspondence, SJCEHD stated that the additional analyses for waste oil constituents requested in their January 8, 2003 letter were not completed In the April 30, 2004 Response .Letter/Site Investigation Work Plan, Cambria maintained that based on the above information, this investigation was complete and no further investigation for waste oil constituents was warranted in soil or groundwater beneath the site SJCEHD's June 14, 2004 correspondence states, "In EHD's March 22, 2004 correspondence/work plan comarient letter, Shell was advised to analyze the ground water samples from the pending and approved CPT boring in the `down-gradient' area of the waste oil UST area for the same constituents detected in SB-2 to confirm and possibly delineate this area " The CPT investigation SJCEHD refers to was completed during August 2003, several months before SJCEHD drafted their March 22, 2004 letter As discussed at length above, Cambria proposed sampling well S-3 for waste oil constituents in the November 19, 2002 work plan SJCEHD approved this work plan in their January 8, 2003 letter and did not indicate that the proposed scope of work was inadequate In fact, SJCEHD agreed with Shell's conclusions and requested additional analyses be collected from groundwater in the waste oil vicinity Shell complied with this request for additional analyses In accordance with RWQCB guidelines, Shell has outlined all planned work in work plans submitted by Cambria, obtained written approval of these work plans from SJCEHD, and then implemented the work as proposed Therefore, Shell was quite surprised to learn that SJCEHD does not consider the waste oil investigation adequate Furthermore, in their June 14, 2004 letter, SJCEHD advises that costs to perform additional waste oil investigation may not be reimbursed by the Underground Storage Tank Cleanup Fund (USTCF) because Shell did not comply with its directives It is clearly demonstrated above that Shell did comply with SJCEHD's requests and that USTCF reimbursement is warranted for future investigation activities Shell contends it would save all parties considerable effort and be more cost-effective if SJCEHD would not approve work it does not deem adequate at the time the work plan is submitted by Shell's consultant Cambria provides a site history listing previous site work in any work plan and report for SJCEHD's review to prevent duplications of work Although Shell maintains that the waste oil UST investigation is complete and no further investigation for waste oil constituents is . warranted, Cambria proposes additional investigation, as requested by SJCEHD, below 5