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California6egional Water Quality CoA61 Board <br /> Central Valley Region <br /> Katherine Hart Chair <br /> Matthew Rodriquez 11020 Sun Center Drive,#200,Rancho Cordova,California 95670-6114 Edmund C.Brown Jr. <br /> Secretaryfor (916)464-3291 •FAX(916)464-4645RECEIVED <br /> Governor <br /> www <br /> Environmental Protection hup:// .waterboards.ca.gov/centralvalley <br /> 13 January 2012 1 2012 <br /> ENVIRONMEW AL HEALTH <br /> PERMIT/SERVICES <br /> Mr. Carol Campagna <br /> Shell Oil Products US <br /> 20945 South Wilmington Avenue <br /> Carson, CA 90810 <br /> SHELL STOCKTON TERMINAL, 3515 NAW DRIVE, STOCKTON, SAN JOAQUIN COUNTY <br /> California Regional Water Quality Control Board, Central Valley Region (Central Valley Water <br /> Board) staff reviewed the 30 November 2011 letter (Letter) submitted by Conestoga-Rovers <br /> and Associates (CRA) on behalf of Shell Oil Products US (Shell) for the Shell Stockton <br /> Terminal at 3515 Navy Drive in Stockton (Site). In 2011, Shell completed the design of the <br /> soil vapor extraction and air sparge (SVE/AS) system. The Letter states that downgradient <br /> groundwater concentrations are defined and source area concentrations are stable to <br /> decreasing. Shell also states that the bids to install the previously approved SVE/AS system <br /> are significantly greater than anticipated. The Letter states that the Site conditions have <br /> changed since approval of the SVE/AS system and requests preparation of a Corrective <br /> Action Plan (CAP) prior to system construction. <br /> Central Valley Water Board staff concur with Shell's request to reevaluate Site conditions prior <br /> to installation of an active remediation system. By 15 February 2012, Shell needs to prepare <br /> and submit a CAP that should include an evaluation of current Site conditions, an update on <br /> groundwater concentration trends, and an evaluation of remedial alternatives. Shell may not <br /> eliminate the proposed and approved remediation method exclusively because of cost. In <br /> addition, the Letter references the State Water Resources Control Board Draft Low-Threat <br /> Underground Storage Tank Closure Policy. This is a draft policy for underground storage <br /> tanks that has not been adopted. The policy may not be adopted; if adopted, may be revised <br /> prior to adoption; or aspects may not apply to aboveground storage tanks. <br /> If you have any questions regarding this letter, you may contact me at (916) 464-4819 or <br /> kshelton waterboards.ca. ov. <br /> RISTI SHELTON, P.E. <br /> Water Resources Control Engineer <br /> cc: Ms. Adrienne Ellsaesser, San Joaquin County Environmental Health Department, <br /> Stockton <br /> Ms. Aubrey Cool, Conestoga-Rovers and Associates, Sonoma <br /> Ms. Rita Koehnen, Port of Stockton, Stockton <br /> Mr. Miguel Torres, Shell OPUS, Stockton <br /> Mr. Mark O'Brien, ERS, Walnut Creek <br /> California Environmental Protection Agency <br /> ped Recycled Paper <br />