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0 <br /> California Regional Water Quality Control Board <br /> Central Valley Region <br /> ion <br /> Robert Schneider,Chair 0 <br /> Terry Tamminen Arnold Schwarzenegger <br /> Secretary for Sacramento Main Office Governor <br /> Environmental Internet Address: http://www.swreb.ca.gov/rwgcb5 <br /> Protection 11020 Sun Center Drive#200 Rancho Cordova,CA 95670-6114 <br /> Phone(916)464-3291 Fax(916)464-4797 <br /> D <br /> 13 April 2004 u <br /> APR 14 2004 <br /> Mr. Jeff Goold EWIRUNI&ITHEALTH <br /> Shell OPUS PERMIT/SERVICES <br /> 2555 - 13th Ave SW <br /> Seattle, WA 98134 <br /> REVIEW OF SUMMARY REPORT & WORK PLAN FOR GROUNDWATER AND SOIL <br /> INVESTIGATION, FORMER SHELL CRUDE OIL PIPELINES —MOUNTAIN HOUSE ROAD, <br /> TRACY, SAN JOAQUIN COUNTY <br /> Staff of the Central Valley Regional Water Quality Control Board(Regional Board)has reviewed the <br /> 15 March 2004 Summary Report(Report) and the 31 March 2004 Workplan for Groundwater and Soil <br /> Investigation (Work Plan) submitted by Clayton Group Services, Inc. (Clayton) on behalf of Shell Oil <br /> Products Company(Shell) for the former Shell Central Valley Crude Oil Pipeline near the intersection of <br /> Mountain House Parkway and Grant Line Road in Tracy(site). The Report summarizes the soil and <br /> grab groundwater sampling results from trenching and a large excavation remedial activity along the <br /> former Shell crude oil pipeline. The sampling was conducted by both Clayton and another consultant <br /> hired by the landowner. <br /> Based on the sampling results from the more than 150 borings, Shell has submitted the Work Plan to <br /> collect additional soil and grab groundwater samples in areas where the pollution was not defined. The <br /> Work Plan proposes to collect soil and grab groundwater samples from 27 borings and to install six <br /> temporary groundwater monitoring wells. The monitoring wells will need to be destroyed in the autumn <br /> of 2004 due to the impending housing development construction. <br /> We have the following comments on these reports: <br /> 1. The laboratory analytical data packages do not include case narratives. All future report <br /> submittals that include laboratory analytical data packages must include case narratives. <br /> 2. The Work Plan is unclear on how the soil will be stored until proper disposal because it refers to <br /> stockpiling the soil and placing in it 55-gallon drums. Shell needs to have investigative-derived <br /> waste (IDW) storage, sampling, and disposal plans that are clear to all staff working on the <br /> project prior to commencing the investigation. Due to the area being highly active with <br /> construction activities, the IDW must be clearly labeled, secured, and removed as quickly as <br /> possible. <br /> California Environmental Protection Agency <br /> �Ci'Recycled Paper <br />