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ENVIRONMENTAL HEALTH DEPARTMENT <br /> " , SAN JOAQUIN COUNTY <br /> Unit Supervisors <br /> Donna K.Heran,R.E.H.S. Carl Bergman,R.E.H.S. <br /> 304 East Weber Avenue, Third Floor g <br /> Director Mike Huggins,R.E.H.S.,R.D.I. <br /> Al Olsen,R.E.H.S. Stockton, California 95202-2708 Douglas W.Wilson,R.E.H.S. <br /> • 69C'FORN�P• Program Manager Telephone: (209) 468-3420 Margaret Lagorio,R.E.H.S. <br /> Laurie A.Cotulla,R.E.H.S. Fax: (209) 464-0138 Robert McClellon,R.E.H.S. <br /> Program Manager Mark Bareellos,R.E.H.S. <br /> KAREN PETRYNA JUL 1 8 2003 <br /> SHELL OIL PRODUCTS US <br /> PO BOX 7869 <br /> BURBANK CA 91510-7869 <br /> RE: Shell-branded Station Site Code:506171 <br /> 2494 E. Fremont St. RO#: 0000251 <br /> Stockton, CA., 95205 <br /> San Joaquin County Environmental Health Department (EHD) has reviewed Site <br /> Investigation Work Plan/Response Letter dated June 27, 2003 as submitted by <br /> Cambria Environmental Technology, Inc on June 30, 2003 and has the following <br /> comments. <br /> On May 21, 2003 EHD required SHELL to investigate the vertical extent of <br /> methanol and 1,2-DCA in the groundwater in the areas of monitoring wells "S-1- <br /> 85" and "S-3-84" due to high levels of groundwater contamination detected in <br /> previous groundwater sampling events. <br /> The above noted work plan included discussion why methanol was not going to <br /> be investigated further and a proposal to place soil borings in the areas of <br /> concern and sample the soil at 50, 60, 70, 80, and 95 feet below grade for total <br /> lead only by EPA Method 6010. <br /> EHD has discussed the work plan with the Central Valley Regional Water Quality <br /> Control Board (CVRWQCB). This proposal does not meet the intent or the <br /> requirements needed to support conclusions for vertical delineation of methanol <br /> and 1,2-DCA in the groundwater. Delineation of the extent of groundwater <br /> contamination must be demonstrated by groundwater data collected at areas <br /> and depths of concern. The premise that if lead is not found in the soil that the <br /> 1,2-DCA in the groundwater was not from the gasoline release is not acceptable. <br /> Therefore the work plan is not approved. <br /> Methanol is a break down product of fuel oxygenates. Further analysis for <br /> methanol is required and if confirmed to be in the groundwater, the extent must <br /> be defined. <br />