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, <br /> r � • <br /> STATE OF CALIFORNIA—ENVIRONMENTAL PROTECTION AGENCY PETE WILSON,Governor <br /> CALIFORNIA REGIONAL WATER QUALITY coWrnmip PriC!!I 111 <br /> CENTRAL VALLEY REGION - <br /> 3443 ROUTIER ROAD,SUITE A VICE <br /> PHONE: (916)255.3000SACRAMENTO,CA 27-3098 95 HIR 29 Pu 1: 07 <br /> FAX: (916)255-3015 <br /> 27 March 1995 <br /> Mr. Darren Denning <br /> Shell Oil Company <br /> P.O. Box 4848 <br /> Anaheim,CA 92803 <br /> SHELL DISTRIBUTION FACILITY, 3515 NAVY DRIVE, STOCKTON: <br /> REVIEW OF 1994 ANNUAL REPORT (CASE NO. 3007) <br /> We have reviewed the Annual Monitoring Program Report - 1994 and the Quarterly Report- <br /> Fourth Quarter 1994, which were prepared for Shell by Pacific Environmental Group (PACIFIC) <br /> and received by us on 3 February 1995. Our review determined that the Report does not provide <br /> an adequate discussion of the effectiveness of the monitoring system and that it draws some <br /> conclusions regarding definition of the plume,offsite migration, and effectiveness of the remedial <br /> action that are not completely supported by available data. It also does not provide an estimate of <br /> when the Soil Vapor Extraction System(SVE) will begin operating. Since the SVE is not yet <br /> operating, Shell is in violation of Cleanup and Abatement Order 94-705, which required that both <br /> the SVE and the Ground Water Extraction(GWE) systems be operational by 1 December 1994. <br /> The attached memorandum notes potential deficiencies in the plume definition and the monitoring <br /> system, and provides a site overview as a result of the change in Board staff responsibilities for <br /> this project. The memo also lists several recommendations for future actions. As a result of this <br /> review, we request: <br /> 1. Shell's consultants should investigate the significance of the "atypical"diesel analytical results, <br /> and determine whether these results suggest the presence of other hydrocarbon product(s), <br /> additional on- or off-site sources,or could be the result of reactions undergone by the diesel. <br /> 2. Shell shall install the proposed new monitoring wells 28 and 29 as soon as practicable, and <br /> inform us at least three working days in advance so that we may observe and/or split samples if <br /> desired. The results of sampling of the new wells should be reported to us as soon as they are <br /> available. The next monitoring report submitted under Monitoring and Reporting Program <br /> 94-801 should include discussion of the significance of these results. <br /> 3. Shell should continue monitoring to assess the apparent ground water impacts at MW-19 and <br /> the presence of contaminants in DW-1. Sampling results from these wells and wells MW-25, <br /> 26, and 27 should be assessed with respect to the continuing presence of apparent off-site <br /> contamination, and with respect to any possible effects from the Ground Water Extraction <br /> (GWE) system. These results should be considered in preparation of the remedial action plan <br /> (RAP) for Secondary Source Area 3 (SSA-3),which is required by Cleanup and Abatement <br /> Order (CAO) 94-705 and is due 1 April 1995. If continued monitoring of MW-19 shows <br />