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Ms Shelby Lathrop - 2 - 25 November 2009 <br /> Former Tosco Bulk Terminal No 13 <br /> injection points are clustered around source area wells MW-2 & MW-14, offsite well MW-8, and <br /> downgradient well clusters MW-16/MW-17B/MW-18C and MW-20/MW/21B/MW/22C. The <br /> highest concentrations of COCs are generally observed in MW-17B. However, MW-2 generally <br /> contains elevated concentrations of TPHd. <br /> Some of the proposed well installations and abandonments were performed between 9 and 14 <br /> July 2009. Due to access restrictions at the Site, however, IP-13 could not be installed, the <br /> proposed modifications to P6 could not be performed, and IP-2 and IP-3 could not be <br /> abandoned. ConocoPhillips reportedly is continuing to correspond with the Port of Stockton to <br /> resolve the access issues and complete the proposed work. <br /> Our comments are: <br /> 1. The dramatic DO concentration increases observed in the downgradient well clusters on 13 <br /> August and in subsequent bi-weekly monitoring events greatly exceed the 10 mg/L target <br /> concentration. ConocoPhillips will continue the pilot study for two more quarters, through <br /> the first quarter of 2010. In the First Quarter 2010 Monitoring Report, ConocoPhillips needs <br /> to provide an evaluation of the remediation effort and recommendations for future work at <br /> the site. <br /> Z The Third QMR contains no update on ConocoPhillips' negotiations for site access to <br /> complete final well installation and abandonment. Given the current groundwater <br /> concentrations and the status of remediation, the well installations may no longer be <br /> necessary. If the issue has not yet been resolved by the end of next month, please provide <br /> an update on this matter in the fourth quarter report. <br /> If you have any questions regarding this letter, you may contact me at (916) 464-4811 or <br /> betaylor@waterboards.c .gov. <br /> BRIAN TAYLOR P.G. <br /> Engineering Geologist <br /> cc: Mr. Harlin Knoll, San Joaquin County Environmental Health Department, Stockton <br /> Mr. Richard Stiffler, City of Stockton — Department of Municipal Utilities, Stockton <br /> Ms. Debbie Callie, Port of Stockton, Stockton <br /> Mr. Mark O'Brien, Port of Stockton/ERSC, Alamo <br /> Mr. Jeff Kasper, Deputy Port Director, Environmental Planning & Facilities, Stockton <br /> Mr. Sean Coyle, Stantec, Rancho Cordova <br /> Mr. Joe Aldridge, NuStar Energy, Texas <br /> Ms. Carol Campagna, Shell OPUS, Carson <br />