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f I L E AR4 <br /> ENVIRONMENTAL HEALTH DEPART <br /> Pay,„ SAN JOAQUIN COUNTY <br /> a°,�,.r✓:.co <br /> '* t� Donna K.Heron,R.E.H.S. Unit Supervisors <br /> Director 304 East Weber Avenue, Third Floor Carl Borgntan,R.E.H.S. <br /> Al Olsen,R.E.H.S. Stockton, California 95202-2708 Mike Huggins,R.E.H.S.,R.D.I. <br /> Douglas W. Wilson,R.E.H.S. <br /> • c�.� FORK' Program Manager Telephone: (209) 468-3420 Margaret Lagorio,R.E.H.S. <br /> Laurie A.Co R.E.H ..E.H.SFax: (209) 464-0138 Robert McClellon,R.E.H.S. <br /> Program Man Manager Mark Barcellos,R.E.H.S. <br /> KAREN PETRYNA <br /> SHELL OIL PRODUCTS US JUN 17 2004 <br /> 20945 S WILMINGTON AVE <br /> CARSON CA 90810 <br /> RE: Shell-branded Station Site Code:506171 <br /> 2494 E. Fremont St. ROM 0000251 <br /> Stockton, CA., 95205 CUF#: 016093 <br /> San Joaquin County Environmental Health Department (EHD) has reviewed <br /> Ground Water Monitoring Report— First Quarter 2004 Preliminary Findings of <br /> Offsite Research, Work Plan Approval Response Letter(Letter) dated May 25, <br /> 2004 as submitted by Cambria Environmental Technology, Inc and has the <br /> following comments. <br /> On September 22, 2003, EHD conditionally approved Revised Site Investigation <br /> Work Plan dated August 28, 2003. As of this date, the offsite work included in <br /> this plan has not been started. <br /> In the September 22, 2003 work plan review letter, EHD clearly stated that <br /> Shell's rationale for not investigating deeper zones for 1,2-DCA was "not <br /> acceptable"and Shell was directed "to continue investigating deeper zones in all <br /> areas where existing, deepest monitoring well laboratory data confirms the <br /> presence of a petroleum constituent. All areas and depths with detectable <br /> petroleum impacts are to be laterally and vertically investigated and delineated." <br /> In this most recent Shell submittal, modifications were proposed to the original <br /> work plan that EHD conditionally approved. The modifications were to not <br /> perform the off site investigation north of the site (not drilling the three soil <br /> borings SB-26, 27, & 28) and to not perform vertical assessment "in the source <br /> area". <br /> Shell's rationale for not completing the required and approved borings offsite is <br /> that a gas station was previously located on the property that may be the source <br /> of the 1,2-DCA found in the water collected from S618. EHD cannot support this <br /> allegation because there is no documented soil contamination beneath the <br /> reported former underground storage tank (UST) system located at the site that <br /> would demonstrate that the former UST system leaked. <br />