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Former Shell Oil Pipelines -3 - • 28 October 2013 <br /> Hansen Road <br /> CRA also contends that shallow groundwater will not be used because development of <br /> the site may include water supplied by the City of Tracy. The Water Quality Control <br /> Plan (Basin Plan) designates the beneficial use of all groundwater in the Central Valley <br /> as municipal and domestic water supply. Furthermore, groundwater in the area of the <br /> site is currently being used for potable water supply. <br /> CRA proposal to utilize RBCS as cleanup goals for the unsaturated zone is not <br /> appropriate for the site. Although the proposed RBCs may be protective of human <br /> health, with elevated concentrations of TPH-c remaining in soil, the RBCs have not <br /> been shown to be protective of groundwater quality. Therefore, in accordance with the <br /> Water Code and the policies promulgated thereunder, the groundwater beneath the <br /> pipeline must be cleaned up to water quality objectives. <br /> Based on site conditions and monitoring results, Shell Incorporated (Shell) must submit <br /> a work plan by 9 December 2013 to remove the remaining contaminants in soil, so as <br /> to prevent further impacts to groundwater beneath the site. In the work plan, include a <br /> proposal to delineate TPH-c and constituents. Shell may suspend attempts to remove <br /> LNAPL from the monitoring wells until such time as a comprehensive groundwater <br /> cleanup plan can be developed. Central Valley Water Board staff will consider your <br /> proposal to reduce groundwater monitoring in certain wells, where warranted. <br /> If you have questions or would like to schedule a meeting to discuss the requirements, <br /> please contact me at (91 ) 464-4728. <br /> MICHAEL SMITH <br /> Environmental Scientist <br /> cc: Ms. Adrienne Ellsaesser, San Joaquin County Environmental Health Department <br /> Stockton <br /> Mr. Dan Lescure, Conestoga-Rovers and Associates, Sonoma <br /> Ms. Gaylyn Frosini, FedEx Ground, 1000 FedEx Drive, Moon Township, PA <br /> 15108 <br />