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Shell Oil Company <br /> any P <br /> P.O. Box 4848 <br /> 511 N.Brookhursl Street <br /> VIA FEDERAL EXPRESS Anaheim,California 92803 <br /> July 16, 1992 <br /> Ms. Wendy Cohen MIN Q s r <br /> California Regional Water Quality Control Board �­ *LI � d <br /> Central Valley Region <br /> 3443 Routier Rd. JUL 2 9 1992 <br /> Sacramento, CA 95827 <br /> GNVIR9NMENTAL HEAI.1'H <br /> RE: SHELL OIL COMPANY DISTRIBUTION PLANT PERMIT/50VIUO <br /> 3515 NAVY DRIVE, STOCKTON, CA <br /> Dear Ms. Cohen: <br /> In response to your letter, dated June 3 , 1992 , and our June <br /> 23, 1992 meeting Shell has retained Harding Lawson Associates <br /> to prepare a work plan for off-site characterization of <br /> groundwater. Find attached, dated July 13 , 1992, the subject <br /> work plan. As agreed upon at the June 23rd meeting, this <br /> work plan is to be submitted to the regional board by July <br /> 17 , 1992. Also, as agreed, Shell is moving forward with <br /> plans to install two additional total fluids groundwater <br /> recovery pumps as an interim remedial measure. <br /> As you will see, a deep well has not been proposed in the <br /> work plan. As we understand it, your request for <br /> installation of a deep well to address vertical gradients was <br /> based on data accumulated at the Arco products terminal <br /> located on the corner of Washington and Stork Streets. The <br /> following are some of Shell ' s concerns with the data <br /> collected and presented in the report. <br /> 1. Shell considers mud rotary drilling as one of the <br /> least desirable techniques for drilling <br /> environmental groundwater monitoring wells. <br /> 2 . Some of the analytical data reported is suspect in <br /> Shell ' s opinion. For example, some of the benzene <br /> analytical results have exceeded the maximum <br /> theoretical solubility (18 mg/1) for benzene in <br /> groundwater. <br /> The aforementioned reasons, along with arguments previously <br /> presented lead us to the conclusion that installation of deep <br /> wells to address vertical gradients is not appropriate at <br /> this time. <br />