SITE INFORMATION AND CORRESPONDENCE

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Harlin Knoll EH From: Jim Barton bbarton@waterboards.ca.gov] Sent: Friday, December 21, 2007 12:48 PM To: jneely@craworld.com; Margaret Lagorio [EH] Cc: Harlin Knoll [EH] Subject: Requests for Shell No. 204-7884-0901, 3725 Tracy Blvd, Trac y,San Joaquin County Hello Joe, We are currently considering the 2 November 2007 San Joaquin County Environmental Health Department's Closure Concurrence Request to the Regional Board for Shell No. 204-7884-0901, 3725 Tracy Blvd, Tracy. In a meeting with the County on 17 October 2007, 1 asked that Shell address the two TPHd hits in soil at sample locations D-3 and D-6, which were sampled during the dispenser upgrades. The soil TPHd concentrations (2, 500 and 3, 000 mg/kg) exceed the Region 2 soils ESLs for Gross Contamination and Direct Exposure, which are a human health concerns and for Leaching to Groundwater, which is a water quality concern. The 2006 Closure Report does not address why these soil concentrations should not be considered a threat to human health or water quality, but states the TPHd results chromatographs do not resemble TPHd and are more consistent with Stoddard Solvent or paint thinner. Subsequent to the 17 October 2007 meeting with the County, I was informed by the County that Shell would not do an additional investigation to address our concerns. In order to move this closure concurrence request forward, additional justification (other than Shell will remove the soil when they take the dispensers out of service, which is not adequate) is needed. You must support why the residual contamination does not now, and will not in the future, pose a threat to water quality or to workers. As such, please provide the following: 1) By 4 January 2008, a copy (either electronic or paper) of the 2004 Investigation Report with the all included lab sheets. 2) By 16 January 2008, a letter response with text supporting a technical rationale why these two TPHd hits are not a threat to human health and water quality, and include all applicable the data to support those conclusions. Hello Margaret, Per our conversation this morning in which you said that 1 could email Shell 's consultant directly with our request for additional information, I am now requesting an extension until 1 February 2008 for our response to your Closure Concurrence Request for the above site, in order for us to receive and evaluate the above requested information. Thanks. Jim Barton James L.L. Barton, P.G. Engineering Geologist California Regional Water Quality Control Board Central Valley Region, 11020 Sun Center Drive, Suite 200, Rancho Cordova, CA 95670 office (916) 464-4615 fax (916) 464-4704 1