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California Regional Water Quality Control Board _ <br /> Central Valley Region + <br /> Karl E. Longley,ScD,P.E.,Chair. <br /> Arnold <br /> Linda S.Adams 11020 Sun Center Drive#200,Rancho Cordova,California 95670-6114 <br /> Schwavernegger <br /> Secreraryfor <br /> Phone(916)464-3291 •FAX(916)464-4645 Governor <br /> Environmental http://www.waterboards.ca.gov/centralvalley <br /> Protection RECE V E <br /> 17 September 2009 <br /> SEP 2 2 2009 <br /> Ms. Carol Campagna ENVIRONMENT HEALTH <br /> Shell Oil Products US PERMIT/SERVICES <br /> 20945 South Wilmington Avenue <br /> Carson, CA 90810 <br /> GROUNDWATER MONITORING AND REMEDIATION REPORT, SHELL STOCKTON <br /> TERMINAL, 3515 NAVY DRIVE, STOCKTON, SAN JOAQUIN COUNTY <br /> Regional Water Quality Control Board, Central Valley Region (Central Valley Water Board) <br /> staff reviewed the 31 July 2009 Groundwater Monitoring and Remediation Report, 2009 Semi- <br /> Annual Report— 1St and 2"d Quarters (Semiannual Report) 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). Groundwater monitoring at the Site is <br /> conducted pursuant to Monitoring and Reporting Program (MRP) No. R5-2005-0810. <br /> The Semiannual Report summarizes groundwater conditions observed at the Site between <br /> February and May 2009. The prevailing horizontal and vertical groundwater gradients are <br /> variable and downward, respectively. No separate phase hydrocarbons (SPH) were observed <br /> in monitoring wells during the first half of 2009. Groundwater pollution at the Site is divided into <br /> three source areas (SAs) designated as SA1, SA2, and SA3. During the first half of 2009, <br /> maximum concentrations of total petroleum hydrocarbons as gasoline (TPHg), TPH as diesel <br /> (TPHd), and benzene were observed in SA2 well MW-10 at 35,000 micrograms per liter <br /> (Ng/L), 12,00 pg/L, and 14,000 pg/L, respectively. MW-1, in SA1, contained the highest <br /> concentrations of methyl tertiary butyl ether (MTBE) and tertiary butyl alcohol (TBA) at 20,000 <br /> pg/L and 15,000 pg/L, respectively. <br /> Groundwater remediation at the Site is being performed by operating a groundwater extraction <br /> (GWE) system which pumps water from MW-1. The GWE has been operated since <br /> 10 April 2006. During the first half of 2009, the GWE treated about 43,299 gallons of water at <br /> an extraction rate of 0.16 gallons per minute and removed about 8.8 pounds (lbs) of TPHg, <br /> 1.4 lbs of benzene, and 6.4 lbs of MTBE. The Semiannual Report states that performance of <br /> quarterly groundwater monitoring and operation of the GWE will continue. A report with air <br /> sparge/soil vapor extraction (AS/SVE) pilot test results will be submitted to the Central Valley <br /> Water Board by 1 November 2009. <br /> Our comments are presented below. <br /> 1. The Semiannual report does not provide an adequate update on the operation of the <br /> AS/SVE pilot test. Reporting requirement (i) of MRP No. R5-2005-0810 requires Shell to <br /> report "...the status of any ongoing remediation, including cumulative information on the <br /> mass of pollutant removed from the subsurface, system operating time, the effectiveness <br /> of the remediation system, and any field notes pertaining to the operation and maintenance <br /> California Environmental Protection Agency <br /> pia Recycled Paper <br /> L <br />