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California ►onal Water Quality Cont I Board <br /> l\v- Central Valley Region <br /> Karl E. Longley,ScD, P.E.,Chair. se <br /> Linda S.Adorns <br /> Secremri for Sacramento Main Office Arnold <br /> Einnranmeraml <br /> 11020 Sun Center Drive#200.Rancho Cordova.Cal ifomia 95670-6114 Schwarzenegger <br /> Prorecuon Phone(916)464-3291 •FAX(91(5)4644645 Governor <br /> hl ,J ntralvalley7(" � f �U <br /> 31 January 2008 <br /> Fps - 1 2008 <br /> Mr. Jeff Goold <br /> Shell Oil Products US EINSONIVIENT HEALTH <br /> DC:O M1BIT/�Cpvl�Cr <br /> 20945 South Wilmington Avenue - • <br /> Carson, CA 90810 <br /> SITE INVESTIGATION WORK PLAN ADDENDUM, SHELL STOCKTON TERMINAL, <br /> 3515 NAVY DRIVE, STOCKTON, SAN JOAQUIN COUNTY <br /> Regional Water Quality Control Board, Central Valley Region (Regional Water Board) staff <br /> reviewed the 15 January 2008 Site Investigation Work Plan Addendum (Addendum) submitted <br /> by Conestoga-Rovers and Associates (CRA) on behalf of Shell Oil Products US (Shell) for the <br /> Shell Stockton Terminal at 3515 Navy Drive in Stockton (Site). <br /> The Addendum was submitted in response to comments in our 14 September 2007 letter and <br /> discussions in a 14 December 2007 teleconference. The teleconference was attended by <br /> Mr. Jeff Gaarder and Mr. Dan Lescure of CRA, and Mr. Jeff Goold of Shell. Our letter <br /> commented that three of the proposed borings should be relocated to the three source areas <br /> (SAS). We also commented that in order to provide monitoring data at the vertical extent of <br /> pollution (1) if pollution was detected in the deeper zone in the vicinity of DW-2, the borings <br /> should be converted to monitoring wells, and (2) monitoring wells must be installed in the three <br /> SAS. Shell concurred with this strategy during the teleconference. <br /> The Addendum however, states that "... cone penetrometer test (CPT) drilling equipment in <br /> combination with depth-discrete Hydropunch groundwater sampling will be used to complete <br /> the assessment as originally proposed. Additionally, Geoprobe's Membrane Interface Probe TM <br /> (MIB) [sic] will be used to assist with estimating the vertical extent of the dissolved-phase <br /> petroleum constituents in the three source areas." <br /> Our comments on the Addendum presented below. <br /> 1. CRA's recommendation to forgo monitoring well installations contradicts the agreements <br /> reached in our 14 December teleconference discussions during which Shell concurred that <br /> the investigation would include monitoring well installation. Our rationale for requiring well <br /> installation to.complete this investigation was explicitly stated in our 14 September 2007 <br /> letter. It is not clear how Shell can effectively monitor cleanup progress in the deep zone <br /> without the benefit of data obtained from monitoring wells or subsequent drilling <br /> mobilizations to obtain additional grab groundwater data. Regional Water Board staff will <br /> review the results of this investigation to determine whether the well installations can be <br /> deferred pending the results of future remedial activities. <br /> 2. In the three SAS, the Addendum proposes to collect depth discrete groundwater samples <br /> below the lower extent of pollution within the source areas. Shell estimates this depth to be <br /> California Environmental Protection Agency <br /> Zd Recycled Paper <br />