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San Joaquin County DIRECTOR <br /> p Donna Heran , REHS <br /> U 1 N <br /> Environmental Health Department ASSISTANT DIRECTOR <br /> ). j. ._.O <br /> G <br /> 600 East Main Street <br /> Laurie Cotulla, REHS <br /> (}mplg < Stockton, California 95202-3029 PROGRAM COORDINATORS <br /> Carl Borgman, REHS <br /> Mike Huggins, REHS, RDI <br /> �q • =� P Website: wwwsjgov. org/ehd Margaret Lagorio, REHS <br /> � i F oa Phone: (209) 468-3420 Robert McClellon, REHS <br /> Fax: (209) 464-0138 Jeff Carruesco, REHS, RDI <br /> Kasey Foley, REHS bf lul2{� <br /> October 21 , 2008 <br /> Mr. Denis L. Brown Mr. David Hoover <br /> Shell Oil Products US California Fuel Supply Inc. <br /> HSEQ / Science & Engineering 587 Ygnacio Valley Road <br /> 20945 S. Wilmington Ave. Walnut Creek , CA 94596 <br /> Carson, CA 90810 <br /> Subject: Former Shell Station Site Code: 1070 <br /> 2575 Country Club Blvd , Global ID#: T0607732095 <br /> Stockton , CA 95204 <br /> The San Joaquin County Environmental Health Department (EHD) discussed the above subject <br /> site with the Central Valley Regional Water Quality Control Board (CVRWQCB) on October 15, <br /> 2008 . The EHD is concerned that the ground water extraction (GWE) system that was installed <br /> at this site for remediation of the contamination and to control the off-site migration of the <br /> dissolved petroleum hydrocarbon plume has not been in operation since March 2008. The <br /> GWE system was shut down because TBA was detected in the treatment system effluent that <br /> was discharged to the City of Stockton sewer which was a violation of Shell's discharge permit. <br /> The EHD was informed in correspondence from Conestoga Rovers & Associates on May 22 , <br /> 2008, that they were evaluating in-situ chemical oxidation (ISCO) as an alternative treatment <br /> technology for the site and expected the evaluation to be completed in June 2008. On August <br /> 20 , 2008, Denis Brown of Shell also discussed with the EHD and the CVRWQCB the use of <br /> ISCO remediation at the site because Shell did not want to violate their discharge permit again <br /> and could not be assured by vendors that TBA would be completely removed by the treatment <br /> system. In early October, Denis Brown of Shell left voice messages for Margaret Lagorio and <br /> Michael Infurna of EHD that Shell wanted to use ISCO remediation instead of GWE. <br /> During the EHD and CVRWQCB discussion of the site, the ISCO remedial alternative was <br /> determined acceptable as long as Shell can demonstrate that there are a sufficient number of <br /> monitoring wells installed to ensure that the contamination is not migrating off-site. In addition , <br /> it was discussed that since the site at 2725 Country Club is performing ISCO remediation , Shell <br /> may not have to perform bench scale testing and instead may propose a pilot test for their <br /> ISCO remediation . <br /> Although, Shell has discussed the use of ISCO remediation since the GWE system was shut <br /> down in March 2008 , a proposal for ISCO remediation has not been submitted to the EHD to <br /> date. <br /> i <br /> i <br />