Laserfiche WebLink
Water Boards <br /> Central Valley Regional Water Quality Control Board RECEIVE <br /> 19 April 2012 /1' R 2 0 2012 <br /> ENPIERMI SERVIC SL7F1 <br /> Mr. Sam Brenneke <br /> Shell Oil Products US <br /> 20945 South Wilmington Avenue <br /> Carson, CA 90810 <br /> FEASIBLITY STUDYAND CORRECTIVE ACTION, SHELL STOCKTON TERMINAL, <br /> 3515 NAVY DRIVE, STOCKTON, SAN JOAQUIN COUNTY <br /> California Regional Water Quality Control Board, Central Valley Region (Central Valley <br /> Water Board) staff reviewed the 15 March 2012 Feasibility Study and Corrective Action <br /> Plan (Report) submitted by Conestoga-Rovers and Associates (CRA) on behalf of Shell <br /> Oil Products US (Shell) for the Shell Stockton Terminal at 3515 Navy Drive in Stockton <br /> (Site). The Report summarizes the current conditions and evaluates potential remedial <br /> technologies for the Site. <br /> Central Valley Water Board staff concurs with Shell's request to discontinue extracting <br /> groundwater from well MW-1. The groundwater extraction rate from MW-1 averages <br /> only 0.04 gallon per minute and petroleum concentrations in the well are similar to when <br /> the system began operating in 2006. Therefore, the current extraction system is <br /> inefficient and Shell may shut down the pumping operations and include the final <br /> system information in the next monitoring report. <br /> Central Valley Water Board staff is currently evaluating the Report along with the <br /> general approach to petroleum release sites at the Port of Stockton. Board staff will <br /> issue our comments on the Report within 90 days. Our initial review of the Report <br /> discovered the following issues that may affect our conclusions: <br /> • The Report includes cleanup goals based on a number of water quality objectives <br /> (WQOs). Shell did not include our 15 September 1998 Water Quality Control Plan <br /> for the Sacramento and San Joaquin River Basins (Basin Plan) in the list. The <br /> Basin Plan provides the following WQOs 100 pg/L for TPHd and 5 pg/L for TPH as <br /> gasoline (TPH-g). Since the normal detection limit for TPH is 50 pg/L, the default <br /> WQO for TPH-g is 50 pg/L. The WQOs used in the Report are much higher and <br /> are not correct. <br /> • Appendix C of the Report includes trend graphs; however, Shell did not use <br /> complete data sets to assess the decay constants at each monitoring well. The <br /> Report does not include the rationale for selecting the starting dates for the trend <br /> analyses. It is not clear why Shell used partial data sets for each well or <br /> KFRL E. LoNGLC'Y BGD, r.E., CHAIR t PAMELA G. CiREEDON P,E.. GCEE, EXECUTIVE OFFICER <br /> 11020 Sun Gbnbn Orlon#200.Rancho COUIUVV CA 95670 www.AUU.1b..1d,ca poo/cenvaWellSv <br /> tp r evm,n urrn <br />