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t <br /> -T - <br /> 19449 Riverside Drive, Suite 230,Sonoma, California 95476 <br /> CON <br /> ESTOGA-ROVERS Telephone: 7079354850 Facsimile: 7079356649 <br /> &ASSOCIATES www.CRAworld.com <br /> November 9, 2007 <br /> Mr.Brian Taylor <br /> California Regional Water Quality Control Board <br /> Central Valley Region <br /> 11020 Sun Center Drive, Suite 200 <br /> Rancho Cordova, California 95670 <br /> Re: RWQCB's September 14, 2007 Letter <br /> Shell Stockton Terminal UU uull�SIIJJ v <br /> 3515 Navy Drive <br /> Stockton, California NOV 13 2007 <br /> Incident No. 300002 ENVIRONMENT HEALTH <br /> Dear Mr. Taylor: PERMIT/SERVICES <br /> Conestoga-Rovers & Associates (CRA) formerly Cambria Environmental Technology, Inc.,prepared this <br /> letter on behalf of Equilon Enterprises LLC dba Shell Oil Products US (Shell) in response to the Central <br /> Valley Regional Water Quality Control Board's (RWQCB) September 14, 2007 letter to Shell. In this <br /> letter, RWQCB staff provided comments and recommendations on the May 4, 2007 Site Investigation <br /> Work Plan and Feasibility Study(FS). Shell is surprised by the RWQCB's response, given most of these <br /> items were discussed and generally agreed upon at a previous face-to-face meeting held at the RWQCB's <br /> offices on February 8, 2007. Nevertheless, Shell's response to each of these comments is presented <br /> below. <br /> RESPONSE TO COMMENTS <br /> The following provides Shell's response to RWQCB staff comments on Items 1 through 4 and 6 through <br /> 8 presented in the September 14,2007 letter. Shell has no comment regarding Item 5. <br /> Page 2, Item 1: "Shell based its selection of DPE over the other three remedial alternatives primarily on <br /> economic feasibility. However,Regional Water Board staff could not compare the cost of the excavation <br /> and SVE/AS options because Table A-Remedial Alternative Comparison in the FS did not include total <br /> costs for these options. We cannot adequately evaluate the remedial alternatives in the absence of a <br /> complete cost comparison. Table A needs to be revised to include costs for the excavation and SVE/AS <br /> options." <br /> Response: As presented in the FS, "......the current extent of impacted soil is unknown. Due to the <br /> proximity of operating fuel equipment and structures,the costs of excavation can increase significantly if <br /> Equal <br /> Empiny-on <br /> Opportunity Emplpyer <br /> Worldwide Engineering, Environmental,Construction,and IT Services <br />