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Mr. Jeff Goold • - 4 - • 10 October 2008 <br /> Shell Stockton Terminal <br /> provides a dilution factor that is absent in ambient indoor air. In order to more accurately <br /> assess potential vapor intrusion to indoor air at the Site, Shell must collect indoor air <br /> samples and compare the laboratory analytical results to Occupational and Safety Health <br /> Administration (OSHA) standards for the work place to evaluate whether a health hazard <br /> exists and whether institutional controls are needed. <br /> 3. We concur with Shell's conclusions in the Pilot Test Report to prepare a RAP for full-scale <br /> implementation of this technology. During the supplemental testing in MW-37, Shell <br /> calculated that a removal rate for TPHg of about 255 pounds per day was achievable at the <br /> maximum encountered TPHg concentration of 24,000 ppmv. However, this rate was <br /> achieved during a short-term test. It is likely that long-term soil vapor removal rates will be <br /> significantly lower. <br /> By 15 December 2008, please submit the RAP for implementing DPE at the hot spots. If you <br /> have any questions regarding this letter, you may contact me at (916) 464-4811 or <br /> betaylor@waterboards.ca.gov <br /> BRIAN TAYLOR, R.G. <br /> Engineering Geologist <br /> cc: Ms. Margaret Lagorio, San Joaquin County Environmental Health Department, Stockton <br /> Mr. Jeff Gaarder, Conestoga-Rovers and Associates, Sonoma <br /> Mr. Jeffery D. Wingfield, Port of Stockton, Stockton <br /> Mr. Ron Orallo, Shell OPUS, Stockton <br /> Mr. Mark O'Brien, ERS, Walnut Creek <br /> Mr. Sean Coyle, SECOR International Incorporated, Rancho Cordova <br /> Ms. Shelby Lathrop, ConocoPhillips, Sacramento <br />