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Shell Service Station <br /> 4315 Waterloo Road, Stockton <br /> Page 2 <br /> I <br /> in 1\IW-4 with concentration as high as 210 ug/1 in July 2004. Results of annual analyses of <br /> " TBA in MW2 through MW4 have been non-detect, but low concentrations of MTBE have <br /> been detected periodically in these wells. EHD has observed what appears to be conversion <br /> Program.0 MTBE TBE to TBA on a number of Shell in the EHD Local Oversight gram. EHD agrees <br /> that some analytes could be dropped from quarterly samplings, but does not concur with the <br /> sampling scope proposed by Cambria. EHD requests the sampling scope be revised as <br /> follows: <br /> 1. Analyze MW-1 quarterly for TPH-g,MTBE, and TBA. <br /> 2. Analyze MW-4 quarterly for TPH-g and TBA. <br /> 3. Analyze all 4 wells annually for TPH-g,BTE1, and all 5 oxygenates. <br /> 4. Analyze the proposed new wells MW-5,MW-6,and'L\'IW-7 initially for TPH-g, <br /> BTEX,and all 5 oxygenates, then reduce sampling scope to TPH-g, MTBE, and <br /> TBA (unless other oxygenates are detected) quarterly. <br /> Installation of the proposed wells-should be implemented by May 16,2005. The revised <br /> sampling scope should be implemented by second quarter of 2005. <br /> REASONS FOR DISAPPROVAL OF THE WORKPLAN (H&S 25299.37, <br /> subd.(C)(3).): <br /> None. <br /> p l � <br /> DATED March 29 2005 BY <br /> i <br /> Cc: CRWQCB,Central Valley Region—James L. L. Barton, PG <br /> Cc: Cambria—Aubrey Cool,PG <br /> I <br /> I <br />