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• � V <br /> Shell branded service station page 2 <br /> 2494 E. Fremont St, Stockton <br /> work plan comment letter <br /> The due date for the Site Conceptual Model (SCM) has been extended to August <br /> 8, 2003 as requested by Joe Neely. Based on the data and discussions that are <br /> to be included in the SCM, SHELL should be able to support conclusions that the <br /> groundwater contamination on the site is from a source other than the northwest <br /> dispenser area as the soil and groundwater data collected to date indicate or <br /> include recommendations for further investigation to collect the data in the near <br /> future to support that assumption. <br /> EHD will require all areas where all petroleum contamination, including 1,2-DCA <br /> and methanol, has been detected to be laterally and vertically delineated. <br /> Both soil and groundwater laboratory data collected from the site is required for <br /> support of delineation conclusions and delineation is required before a site can <br /> be evaluated for the need and extent of remedial actions. <br /> SHELL is hereby directed to submit a revised work plan by August 19, <br /> 2003. <br /> The proposal is to include methods to obtain groundwater samples from depths <br /> greater than previous samples have indicated petroleum and oxygenates have <br /> been detected. Additionally, groundwater samples are to be collected and <br /> analyzed for the same in all lateral areas further out (offsite) than previous <br /> locations have indicated contaminants are present. <br /> EHD cautions SHELL that repetitive argumentative responses to EHD <br /> requirements/directives and the continued failure to conduct investigations as <br /> directed by EHD will jeopardize reimbursement from the State Water Resources <br /> Control Board (SWRCB) Clean Up Fund (CUF) due to non-compliance and may <br /> result in formal action <br /> Donna Heran, REHS, Director <br /> Environmen al Health Div' ion <br /> Michael J. Infurna Jr., Senior REHS Mar�Lagono, REHS <br /> LOP / Site Mitigation Unit IV Supervisor <br /> MI/ <br /> c: CVRWQCB —James L.L. Barton, Sacramento. <br /> c: Cambria — J. Neely PO Box 259, Sonoma, 95476. <br /> c: SWRCB-CUF — Mark Owens, Sacramento. <br />