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I <br /> I - <br /> Former Shell Station page 2 <br /> 2575 Country Club Blvd . , Stockton August 3 , 2010 <br /> Currently sodium persulfate has not been utilized at any UST sites in San Joaquin County, <br /> therefore the EHD has no direct experience with the interactions of this oxidant and the <br /> soil types typical to this area. The EHD has previously requested information from Shell <br /> that sodium persulfate injection has been approved and successfully used at Central <br /> Valley UST sites. This information has not been received . <br /> The Na concentrations in the groundwater present a significant concern at this site and <br /> the EHD is not convinced that this remedial option is feasible or cost-effective. Until Shell <br /> can support conclusions that sodium persulfate injection at this site is truly a cost- <br /> effective, time-effective , and feasible remedial alternative , the EHD does not approve the <br /> pilot test. With unresolved issues with the WDR permit and the effectiveness of sodium <br /> persulfate in the soil at this site, the EHD cannot approve the addendum at this time. <br /> The EHD recommends two options for Shell to consider and respond to: <br /> 1 . Conduct a background groundwater re-sampling event for Na . In the report of <br /> findings for this event, include relevant field data from other Central Valley UST <br /> sites that have used or are using sodium persulfate. Include a cost-effective <br /> comparison (prices) that compares the estimated cost of using sodium persulfate <br /> to another feasible oxidant injectable and an evaluation of the time each of these <br /> remedial alternatives would require to reach WQOs. <br /> 2 . Submit a revised Feasibility Study that recommends another remedial alternative. <br /> A submittal that incorporates either of the two options is due on Geotracker by September <br /> 16, 2010. <br /> If you have any questions, please call Michael Infurna at (209) 468-3454. <br /> 4��414 <br /> Michael J . Infurna Jr. , REHS Nuel C. Henderson Jr. , PG <br /> Senior Registered Environmental Health Specialist Engineering Geologist <br /> c: Mr. James L. Barton , CVRWQCB , Underground Storage Tank Unit, 11020 Sun <br /> Center Drive, #200 , Rancho Cordova , CA 95670-6114 <br /> Mr. Mark Owens , SWRCB , Division of Clean Water Programs, Underground <br /> Storage Tank Program, P.O. Box 944212, Sacramento, CA 94244-2120 <br /> Mr. Joe Neely, Conestoga-Rovers & Assoc. , 19449 Riverside Dr. , Suite 230, <br /> Sonoma, CA 95476 <br />