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M <br /> ENVIROFP��i_t�� i- Shell Qil Company <br /> P.O.Box 4848 <br /> 93 OCT 12 PM 2: 11 511 N.Brookhurst Street <br /> Anaheim,California 92803 <br /> October 7 , 1993 <br /> Mr. Philip Isorena <br /> California Regional Water Quality Control Board <br /> Central Valley Region <br /> 3443 Routier Rd, Suite A <br /> Sacramento, CA 95827-3098 <br /> RE: EXTRACTION WELLS <br /> SHELL OIL CO. - STOCKTON DISTRIBUTION PLANT <br /> 3515 NAVY DR. , STOCKTON, CA. <br /> Dear Mr. Isorena: <br /> This letter is written to address the RWQCB's concern <br /> that the extraction wells at Shell ' s Stockton Distribution <br /> Terminal have been inactive since April 1993 . <br /> As you know, Shell obtained the one-time discharge permit to <br /> Stockton's POTW this past summer. Obtaining this permit was <br /> a very difficult process. Because of the absence of an <br /> existing pipeline from the Shell Plant to the POTW, this <br /> method for disposal is simply not economically feasible. <br /> Therefore, the extraction system remains inactive because we <br /> do not currently have a viable disposal method. <br /> The hydrogeology of the Stockton site was investigated by <br /> Harding Lawson Associates and discussed in a report, dated <br /> May 3 , 1991, titled Preliminary Hydrogeologic Assessment, <br /> Shell Oil Distribution Facility, Stockton, California. This <br /> report indicates groundwater flow velocities are in the range <br /> of 0. 016 to 0. 19 ft/day (5 to 69 ft/year) . Based on these <br /> velocities and knowledge of the extent of the plume, <br /> migration control does not appear to present an immidiate <br /> threat in the area. Shell does however, recognize the <br /> importance of obtaining the necessary NPDES permit to allow <br /> recontinued operation of the extraction system ,i-n the near <br /> future. <br /> In addition, we have installed the offsite monitoring wells <br /> to the south of our property. This will give us the ability <br /> to detect any migration to the south. These wells will be <br /> monitored and sampled on a quarterly basis. Hydropunch <br /> samples on the west side of the property indicate levels of <br /> contamination increase the closer we get to the Navy <br />