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San Joaquin County DIRECTOR <br /> o <br /> D i N Donna Heran,REHS <br /> ,oP :=, <�o Environmental Health Department ASSISTANT DIRECTOR <br /> 600 East Main Street Laurie Cotulla,REHS <br /> Stockton, California 95202-3029 PROGRAM COORDINATORS <br /> - Mike Huggins,RENS,RDI <br /> • Cq• <br /> Website: ov.o ehd Margaret Lagorio,REHS <br /> este: www <br /> <iFOR��P j9 � Robert McClellon, REHS <br /> Phone: (209)468-3420 Jeff Carruesco,REHS, RDI <br /> Fax: (209) 464-0138 Kasey Foley,REHS <br /> ? 61?..s <br /> July 14, 2009 <br /> Mr. Denis L. Brown Mr. Michael A. Dominquez <br /> Shell Oil Products 2494 E. Fremont Street <br /> 20945 S Wilmington Stockton, CA 95205 <br /> Carson, CA 90810-1039 <br /> Subject: Fremont Shell Station RO#: 0251 <br /> 2494 E. Fremont Street. AP#: 153-280-08 <br /> Stockton, CA 95205 Global ID#: T0607700736 <br /> The San Joaquin County Environmental Health Department (EHD) has recently reviewed <br /> Subsurface Investigation Work Plan (Plan) dated May 21, 2009 submitted by your consultant, <br /> Conestoga Rovers &Associates (CRA). <br /> The Plan is the result of Shell's request to gather additional subsurface data before the revised <br /> Corrective Action Plan is submitted to the EHD. In correspondence dated March 9, 2009, the <br /> EHD required Shell to address the 1,2-dichloroethane (DCA) plume, provide the technical <br /> justification for selecting chemical oxidant injection, and to submit the work plan by May 21, <br /> 2009. <br /> The proposal included in the Plan is to install ten soil borings on and offsite to collect soil and <br /> ground water samples. Shell also proposes to collect soil samples for a bench scale test to <br /> evaluate the feasibility of injecting a chemical oxidant (in situ chemical oxidation — ISCO) into <br /> the subsurface as an interim remedial action. <br /> The EHD could not concur with the technical justification for selecting ISCO over other remedial <br /> alternatives included in Shell's Updated Corrective Action Plan (CAP) dated October 10, 2008 <br /> and requested Shell to "to present the technical basis on which ISCO was selected with enough <br /> detail so that the EHD can properly consider and concur with the selected technology." The <br /> technical justification was not included in the Plan and the EHD requires it to be submitted <br /> before an interim corrective action plan can be approved. As with other remedial technologies, <br /> ISCO is not a universally applicable technology; to be successful, ISCO must be amenable to <br /> site conditions and plume characteristics. <br />