SITE INFORMATION AND CORRESPONDENCE_FILE 2

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Fremont Shell page 2 2494 E. Fremont St., Stockton March 9, 2009 It was not clear to the EHD what reference (guidance) document was used to design the bench scale test (BST). Please be aware that the EHD encourages the use of the Central Valley Regional Water Quality Control Board (CVRWQCB) draft guidance document to be sure to generate the data needed by the CVRWQCB to evaluate the necessity to issue Waste Discharge Requirements (WDR). Please advise the EHD that the BST methodology Shell is planning on using conforms to or is equivalent to the CVRWQCB document. A contingency plan should be included that lists steps to be taken in the field if undesirable byproducts are formed by the use of the ISCO. This plan may be included in the pilot test work plan due at the EHD after the corrective action plan is approved. The EHD listed additional concerns regarding the BST in the July 23, 2008 correspondence and these concerns were not addressed in the revised corrective action plan. The revised corrective action plan is not adequate as submitted and is not approved. [H&S Code 25296.10(3)(c)]. Before the EHD can complete the review of the corrective action plan, the items listed in this correspondence must be satisfactorily addressed. Please submit a revised corrective action plan to the EHD before April 24, 2009 that addresses the concerns noted in this correspondence and the July 23, 2008 letter. The Site Investigation Work Plan included in the revised corrective action plan is not approved at this time. After the EHD has completed its review of the corrective action plan, you will be notified if the work plan is approved or modifications are needed. 1,2-DCA is present in the ground water monitoring wells (S-2, S-5, S-2-85) in the southeast corner of the site. Ground water flow has been to the southeast at times and the EHD requires Shell to sample the drinking water supply well located in the mobile home park southeast of the site. Please collect ground water samples from this well on a quarterly basis beginning immediately and include the data in the quarterly reports due on Geotracker by the 15th of the month following each quarters end. This well is to be sampled for the same LUFT COCs the Shell monitoring wells are sampled for. If you have any ques s please contact Michael Infurna at (209)468-3454. Michael J. Infurna Jr., REHS Nuel C. Henderson Jr., PG Senior Registered Environmental Health Specialist Engineering Geologist MJ I: c: Mr. James L. Barton, CVRWQCB — 11020 Sun Center Dr., #200, Rancho Cordova, CA. 95670 Mr. Mark Owens, SWRCB-CUF — PO Box 944212, Sacramento, CA. 94244 Mr. Michael Murphy, CRA— 19449 Riverside Drive, #230 Sonoma, CA. 95476