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V <br /> Shell Oil Sites <br /> Page 2 <br /> 1267 Country Club,Stockton <br /> EHD does not consider the extent of the waste oil impact to soil and groundwater defined. The <br /> work plan recently submitted has not been approved. An addendum to that work plan will be <br /> prepared that addresses EHD's concerns with the waste oil investigation and provides investigation <br /> down gradient (northeast) of the petroleum fuel contaminant plume. <br /> 2575 Country Club,Stockton <br /> The current proposal for replacement of monitoring well MW5 will not provide the information <br /> required to delineate the extent of the contaminant plume. Additional ground water investigation is <br /> needed in areas where analytical results of soil samples from borings showed the soil to be highly <br /> contaminated. A work plan addendum is to be submitted that proposes placement and construction <br /> of monitoring wells that will provide delineation of the contaminant plume. <br /> 2320 El Dorado Street,Stockton <br /> EHD agreed with Cambria that contaminants might be migrating across El Dorado Street from the <br /> site at 2315 El Dorado Street. It is unknown if the contamination detected in the monitoring wells <br /> at the Shell station is the result of the residual soil contamination from the three UST's that were <br /> removed in 1990 (no further action required letter provided in 1991),a result of new release(s) <br /> between 1991 and the present, or migration of contaminants from the 2315 El Dorado Street site. <br /> EHD requested that an SCM be included in the next quarterly monitoring report (QMM), or by the <br /> 3rd quarter 2005 QMM, that would discuss the contaminant plumes at both sites: <br /> EHD agreed that the enactment of the approved cone penetrometer (CPT)work plan dated October <br /> 4,2004 should be postponed at this time. <br /> Shell agreed to analyze for trichloroethene (TCE) and tetrachloroethene (PCE)in water samples <br /> from MW-3 and MW-4 the next quarter(3rd QMM) since both contaminants were detected in the 4th <br /> quarter 2004 monitoring event. EHD may request additional quarterly sampling of TCE and PCE in <br /> two or more monitoring wells in the future. Cambria suggested that the responsible party of 2315 El <br /> Dorado Street should also include analyses for TCE and PCE on their water samples. EHD <br /> encourages Shell to coordinate sampling and testing with the responsible party for 2315 El Dorado <br /> Street. <br /> As agreed to at the meeting,EHD has completed a cursory review of the history and investigation of <br /> the former waste oil underground storage tank(UST) tank at the 2315 El Dorado Street. In April <br /> 1987,a 200-gallon waste oil UST was removed from the site. Analytical results of the soil sample <br /> collected beneath the UST were non-detect(ND) for TCE and 1.6 micrograms per kilograms . <br /> (ug/kg) of PCE. In October 1993 multiple soil samples were collected from 3 soil borings to 30 feet <br /> below surface grade (bsg) and 1 soil boring to 36 feet bsg that were installed next to the former UST. <br /> Analytical results of all the samples were ND for PCE and TCE. Analytical results of a ground water <br /> sample from monitoring well MW-1 installed next to the former UST in September 1994 were also <br /> ND for PCE and TCE. <br /> EHD also reviewed our Shell station UST file and found that Shell originally reported a 550 gallon <br /> waste oil UST to be at the site but when EHD staff inspected the site in 1986 it was stated that the <br /> UST had been removed prior to 1984 so there is no soil data on the Shell waste oil UST. The file <br /> did have soil sample results from the UST system removal in July 1990 and soil samples SS-1, 5,7, <br /> 10, 11 and 12 all had detections of PCE in the soil samples collected. Please be aware that the <br /> information presented in this letter is based on a cursory review. EHD recommends you perform a <br /> file review of your own. <br />