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November 24, 2008 Ms. Carol Campagna Shell Oil Products US 20945 S. Wilmington Carson, California 90810 Re: October 29, 2008 Inspection Report Shell Stockton Terminal 3515 Navy Drive Stockton, California Incident No. 300002 Dear Ms. Campagna: Conestoga -Rovers & Associates (CRA) prepared this letter in response to San Joaquin County Environmental Health Department's (SJCEHD) October 29, 2008 inspection performed at the referenced site. Specifically, SJCEHD staff noted that Shell did not properly characterize drilling residuals for disposal as indicated on the attached inspection report. CRA's response to this claim is presented below. Soil Disposal Profiling Process The waste stream in question was generated during subsurface drilling activities. In this case, the drill cuttings were generated with a high pressure waterknife used for clearing the boreholes prior to drilling. The waterknife uses clean tap water. Because of the nature of sludge — solids suspended in water — the drilling residuals are classified following Shell's Residual Management Team's (RMT) procedures which specify using soil data for profiling the waste stream. Soil data are used because any contamination to the sludge would originate in the soil. Soil drums that were generated at the terminal were classified based on the attached laboratory analytical report (Calscience 08-04-2322). The analyses used to classify the residuals were TPH purgeable and BTEX by EPA 8260B, TPH extractable and TPH as motor oil by EPA 8015M, and CAM17 metals by EPA 6010. These analyses are sufficient to classify both the soil and sludge since the water is clean tap water and the suspended solids are the same as the soil removed from the boreholes. The analytical report indicates the drilling residuals generated at the terminal are non -hazardous materials using Shell disposal procedures. As shown on page 21 of the certified analytical report ("Laboratory Analysis Request"), the Title 22 hazardous waste testing criteria, aquatic bioassay and STLC, were not required because the analytical results were below the corresponding trigger levels for these tests. The trigger levels are commonly used in the environmental industry and are based on the State of California disposal requirements.