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• � Page 1 of 1 <br /> Lori Duncan [EH] <br /> From: Lori Duncan [EH] <br /> Sent: Tuesday, November 24, 2009 12:04 PM <br /> To: 'den is.l.brown@shell.com'; 'Rosecrance, Ann' <br /> Cc: Nuel Henderson [EH] <br /> Subject: 6131 Pacific <br /> Denis, <br /> Just so were clear, I do not approve further delays in this project. Shell and Cambria have already declared the <br /> site defined; they have already prepared and implemented the CAP they wanted to implement. Contaminant <br /> masses have been determined; insitu prior to remediation and what was removed by the remediation. <br /> MW-3 is the only dirty well that has become submerged; MW-14 was installed specifically to investigate the <br /> shallow water in that area. The MW-4 screen interval is at the top of the water table, concentrations in that well <br /> have always fluctuated and have been higher for 2.5 years. The MW-6 and MW-7 screen intervals are also near <br /> the top of the water table, but they always have been. None of these wells are in the source area, which is where <br /> you should be focusing the groundwater remediation effort. <br /> The EHD approved your 9/9/05 CAP and its proposal to"..Establish a contingency plan to expedite or enhance <br /> remediation, if necessary" and this is what we expected you to do, but the RAP was submitted without it. On <br /> 3/17/09 your consultant, CRA(formerly Cambria)called me on the phone and told me the remediation system <br /> had been shut down. I specifically told him to submit a report and that it must include recommendations for <br /> completion of the groundwater remediation. The 'System Shutdown Request'was submitted two months later <br /> and did not include any recommendations. <br /> In correspondence dated 6/8/09 the EHD notified you of the lacking recommendations and requested that, per <br /> CCR Title 23 Section 2653(c)(8), you submit proposed cleanup actions and a time schedule for implementing <br /> them. This was not received by the EHD. <br /> In correspondence dated 8/21/09 the EHD again requested you submit the proposed cleanup actions and a time <br /> schedule for implementing them and established a deadline for the submittal of 10/9/09. On 9/10/09 <br /> CRA requested and received an extension of this deadline until December 9, 2009. That's two weeks from <br /> tomorrow. <br /> Sincerely, <br /> Lori Duncan, Senior REHS <br /> San Joaquin County <br /> Environmental Health Department <br /> Idu_n_can&jcehd com <br /> (209)468-0337 phone <br /> (209)468-3433 fax <br /> 7/19/2011 <br />