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Shell Gas Station page 2 <br /> 2494 E. Fremont Street, Stockton <br /> COMMENTS AND CONDITIONS: (continued) <br /> • 1,2-DCA and the highest TPHg and Benzene groundwater concentrations <br /> are present in groundwater samples from the area around monitoring well <br /> S-1-85 and borings SB-2, SB-3, and S-1. The proposed total depth of soil <br /> boring SB-19 in this same area is 150' bgs. The analysis proposed for the <br /> soil samples to be collected is lead. No groundwater sample collection is <br /> included. To not collect groundwater samples for analysis at this time in <br /> this "vertically undefined" area is inadequate and not cost-effective. <br /> EHD directs SHELL to collect and analyze multiple depth <br /> groundwater samples from —90' bgs to the total depth of SB-19 in all <br /> 'permeable' zones for TPHg, BTEX, Oxygenates, and lead <br /> scavengers. <br /> • The report of findings for this phase of field work and all future report of <br /> findings are to be formatted in the context of a SCM, added to as data is <br /> gathered, and submitted to EHD immediately following the end of each <br /> phase of field work. <br /> • SHELL's rationale for not investigating deeper zones for 1,2-DCA due to <br /> possible cross-contamination is not acceptable. Methanol detections <br /> previously detected in some deeper borings were later confirmed as non- <br /> detect in the monitoring wells installed in these borings. Based on <br /> repeatable groundwater sampling events, EHD was able to concur with <br /> SHELL conclusions that methanol was not a problem at this site. <br /> Repeatable groundwater sampling data is required to prove hypotheses <br /> such as SHELL is proposing. Without these events, the presence of a <br /> petroleum constituent detected in groundwater grab samples from soil <br /> borings must be confirmed. <br /> EHD hereby directs SHELL to continue investigating deeper zones in <br /> all areas where existing, deepest monitoring well laboratory data <br /> confirms the presence of a petroleum constituent. All areas and <br /> depths with detectable petroleum impacts are to be laterally and vertically <br /> investigated and delineated. <br /> • An EHD well permit application and $89 fee per parcel along with copies <br /> of City of Stockton encroachment permits and all private parcel signed <br /> access agreements should be submitted to EHD with the addendum. <br /> REASONS FOR DISAPPROVAL OF THE WORK PLAN fH&S 25299.37 <br /> subd(c)(3)1: <br /> • Some aspects of the work plan are unnecessary or inadequate. Those <br /> aspects are not approved. <br /> BY: 44A- <br /> hael <br /> ' // Infurna, S for REHS (209)468-3454 <br /> (]Faxed to consultant on: 9 L 3 <br />