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i <br /> h <br /> Mike Infurna [EH] <br /> From : Jim Barton [jbarton@waterboards .ca .gov] <br /> Sent: Monday, March 29 , 2010 7 : 58 AM <br /> To : Mike Infurna [EH] <br /> Cc : Nuel Henderson [EH] <br /> Subject: Re : Shell CRA BST report <br /> Hi Mike , <br /> I reviewed the report briefly, and agree that the text does not provide rationales or data <br /> for some of their conclusions . And lack of laboratory data sheets (summary tables <br /> alone are not acceptable ) indicates an incomplete report . <br /> I also suggest that , since there were many questions that the report did not adequately <br /> address or glossed over, you inform Shell that we discussed the report, and the <br /> Regional Board will require an injection permit issued by this agency before they can <br /> do the pilot study . The injection permit will include a monitoring program and a <br /> contingency plan . <br /> Thanks . <br /> Jim Barton <br /> James L . L . Barton , P . G . <br /> Engineering Geologist <br /> California Regional Water Quality Control Board Central Valley Region , 11020 Sun <br /> Center Drive , Suite 200 , Rancho Cordova , CA 95670 office (916 ) 464-4615 <br /> fax (916 ) 4644704 <br /> > > > " Mike Infurna [ EH]" < Mlnfurna@sjcehd . com > 3/26/2010 11 : 12 AM > > > <br /> Jim , <br /> Happy working Friday . . . <br /> Jim , I got what I consider a weak Bench Scale Test ( BST) report from Shell for a site <br /> of mine that tested Fentons , sodium persulfatecatalized by hydrogen peroxide for <br /> possible injection . <br /> Shell uses a lab in Niagra Falls for this procedure , NOT Primal <br /> as typical with Shell , the field work for this started when the soil sample was collected <br /> May 13 , 2009 . then they broke the water samples in transit to Niagra , and now I get <br /> the BST report dated March 8 , 2010 . <br /> 10 months later . . . is it any surprise why the CUF can 't understand 20 year old sites? <br /> i <br /> II t <br /> f <br />