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ENVIRONMENTAL HEALTH DEPARTMENT Donna K.Heron,R.E.H.S. SAN JOAQUIN COUNTYUnit Supervisors Director 304 East Weber Avenue, Third Floor Carl Borgman,R.E.H.S. Al Olsen,R.E.H.S. Stockton, California 95202-2708 Mike Huggins,R.E.H.S.,R.D.I. Douglas W.Wilson,R.E.H.S. cgtiFoaN;P Program Manager Telephone: (209) 468-3420 Margaret Lagorio,R.E.H.S. Laurie A.Cotulla,R.E.H.S. Robert McClellon,R.E.H.S. Program Manager Fax: (209) 464-0138 Mark Barcellos,R.E.H.S. KAREN PETRYNA OCT 2 7 2004 SHELL OIL PRODUCTS 20945 S WILMINGTON AVE CARSON CA 90810 SINGH, SUKH C & PERMINDER K 880 VICTOR RD LODI, CA 95240 RE: SHELL SERVICE STATION SITE CODE: 1746 880 VICTOR ROAD LODI, CA 95240 San Joaquin County Environmental Health Department (EHD) has received and reviewed Interim Remediation Report/Work Plan/Response Letter(Report), dated 16 September 2004, prepared and submitted on your behalf by Cambria International Technology, Inc. (Cambria). Cambria's primary conclusions in the Report were: • The vertical and lateral extent of MTBE-impacted groundwater has been adequately delineated, except toward the east and southeast, for which additional groundwater monitoring wells have been proposed; • The plume is not actively migrating away from the site; • Pumping test data indicate that it would be difficult and economically infeasible to achieve hydraulic control of the plume of impacted groundwater; • MTBE concentrations are declining due to biodegradation to TBA, which in turn will degrade with declining concentrations in the future; • Interim remediation has been successful (and implies no other remedial actions are necessary at this time) and proposes continued quarterly sampling to monitor the expected additional degradation of the fuel oxygenate contaminants and contraction of the plume; and • No known sensitive receptors are threatened, relieving the necessity for engineered contaminant mass removal or hydraulic control;