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J STIE OF'CALIFORNIA PETE WILSON. Govein or <br /> CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD— <br /> CENTRAL VALLEY REGION <br /> 3443 ROUTIER ROAD, SUITE A v" �� <br /> SACRAMENTO, CA 95827-3098 <br /> PHONE: (916) 00 y, 1 V <br /> FAX: (916) 361-5686-5686 ��T; <br /> AU G 2 8 1992 <br /> ENVIRONMENTAL HEALTH <br /> 20 August 1992 �( Unn1Y/klRV14�Q <br /> Mr. Charles B. Kolesar <br /> Shell Oil Company <br /> P. 0. Box 4848 <br /> 511 N. Brookhurst Street <br /> Anaheim,. CA 92803 <br /> WORK PLAN TO DEFINE THE VERTICAL EXTENT OF SOIL AND GROUND WATER <br /> CONTAMINATION, SHELL OIL COMPANY, STOCKTON FACILITY, CASE NO. 3007 <br /> This is in response to your 16 July 1992 letter which provided Shell ' s <br /> justification for not submitting a work plan to define the vertical extent of <br /> ground water contamination at Shell ' s facility on Rough and Ready Island in <br /> Stockton. <br /> You stated the following justifications: <br /> 1. Our request was based on data obtained at the ARCO facility at the Port <br /> of Stockton fuel terminal ; <br /> 2. Shell considers mud rotary drilling one of the least desirable <br /> techniques for drilling monitoring wells; <br /> 3. Some of the analytical data are suspect, e.g. , benzene results over 18 <br /> mg/l which is the maximum theoretical solubility for benzene in ground <br /> water; and <br /> 4. Arguments previously presented to the Board including the fact that <br /> hydrocarbons float, potential for cross-contamination, and erroneous <br /> results due to sampling of fully penetrating wells. <br /> Following are our responses which appear in the same order as your <br /> justifications: <br /> 1. Our request is based on the absence of sufficient data to define the <br /> vertical extent of soil and ground water contamination; data from a <br /> nearby facility which shows the existence of a vertical gradient and <br /> contamination in the deep zone; and the presence of pumping depressions <br /> east of ARCO which also are likely creating a vertical gradient at Shell <br /> and pulling the contaminants downward. <br />