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i <br /> CAM0 <br /> BRIA <br /> naphthalene, creosote, or PCBs were detected Nickel and zinc were detected up to 9 1 and <br /> 195 ppb, respectively, which are below the MCLS for these constituents (100 and 5,000 ppb, <br /> respectively) Cambria reported these results in our July 24, 2003 Groundwater Monitoring <br /> Report— Second Quarter 2003 and December 4, 2003 Groundwater Monitoring Report— Third <br /> Quarter 2003 <br /> In March 22, 2004 correspondence, SJCEHD states that the waste oil analyses requested in their <br /> January 8, 2003 letter were not completed However, based on the results discussed above, Shell <br /> asserts that this investigation is complete and no further investigation for waste oil constituents is <br /> warranted in soil or groundwater beneath the site <br /> Groundwater Monitoring Well installations in Deeper Zones <br /> Petroleum hydrocarbons were detected in groundwater samples collected from each saturated <br /> zone during the 1998 and 2003 site investigations In our February 27, 2004 Site Investigation <br /> Report, Cambria questioned whether this data is valid or a result of possible cross-contamination <br /> during drilling activities In the March 22, 2004 letter, SJCEHD indicates that it "accepts the <br /> • data as valid " <br /> Shell maintains that there is not enough reliable data to assess the validity of the CPT <br /> groundwater analytical data at this time Therefore, Shell proposes to obtain the needed data by <br /> proceeding with the deeper groundwater monitoring well installations using a phased approach <br /> First, Cambria will install a well in the sandy zone identified at approximately 40 to 45 fbg If <br /> groundwater monitoring analytical data indicate that this zone is impacted by petroleum <br /> hydrocarbons, Cambria will install a well, or additional wells, in deeper sandy zones <br /> SITE INVESTIGATION WORK PLAN <br /> Technical Rationale for Proposed Scope of Work <br /> • The vertical extent of petroleum hydrocarbons in groundwater previously detected in the <br /> vicinity of the former USTs has not been delineated <br /> • Groundwater samples collected from a sand lens identified at depths of approximately 40 to <br /> 45 fbg contain petroleum hydrocarbons <br /> 0943 5 <br />