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Jeff Whitworth <br /> Shell Stockton Terminal , 2 <br /> • 28 February 2007 <br /> In the Report, Shell concludes that the low pum <br /> } <br /> will preclude effective reduction of COCs at the Ping <br /> Site. rate at which the GWE is being operated <br /> On 8 February 2007 Regional Water Board staff met with Shell Oil representatives Mr. Jeff <br /> Withworth, and Mr. Daniel F. Walsh, and Mr. Jeff Gaarder, of Cambria, their Environmental <br /> consultant to discuss remedial options for cleanup at the site. The meetin <br /> based on the following events. <br /> g was requested <br /> In the 1 September 2006 Revised First Semiannual Report, Shell recommended Monitored <br /> Natural Attenuation (MNA) as the preferred remedial alternative for groundwater based on <br /> select groundwater parameters that indicate the potential for natural remediation. In our 2 <br /> October 2006 comment letter, Regional Water Board staff concluded that we did not concur <br /> With the recommendation for MNA as the preferred alternative for groundwater remediation. <br /> Regional Water Board staff requested that Shell should evaluate other remedial options to <br /> cleanup groundwater pollution at the site and provide a feasibility study by 1 February 2006. <br /> Shell responded by requesting a meeting, which convened on <br /> 8 February 2007. During the meeting, Mr. Daniel F. Walsh agreed that, due to the high <br /> contaminant concentrations in groundwater he did not believe MNA to be an effective remedial <br /> that plans for implementing a Pilot Scale Oxygen Injection during the year 2005 were alternative for achieving groundwater quality goals in a reasonable time. Shell also disclosed <br /> cancelled after an internal review concluded that the technology was technically infeasible. At <br /> the conclusion on the meeting Regional Water Board staff concluded that we would contact <br /> Shell with 1) our requirements for evaluation of further remedial alternatives, and 2) a request <br /> for a tour of the Shell Stockton facility. <br /> Our records indicate that on 13 July 2004 the Regional Board provided concurrence with the <br /> selection of a pilot study for oxygen release compound (ORC) from an 8 July 2004 Feasibility <br /> Study (FS) Work Plan. The (FS) Work Plan was prepared on Shell's behalf by The RETEC <br /> Group, Inc. (RETEC), Cambria's predecessor. The Regional Water Board requested a Work <br /> Plan for the ORC injections in a letter dated 15 September 2004. RETEC submitted a Work <br /> Plan Addendum dated 22 November 2004, that revised Shell's selection of pilot study <br /> remedial technology to Oxygen Injection into groundwater. The Regional Board concurred with <br /> the Work Plan in a letter dated 1 December 2004. Shell provided an implementation schedule <br /> via a 31 May 2005 email. Shortly thereafter, personnel changes at the Regional Water Board, <br /> Shell, and the replacement of RECTEC with Cambria appeared to have ultimately contributed <br /> to a delay in the selection and implementation of a pilot scale study. <br /> Our comments on the Report and our recommendations for additional remedial evaluation are <br /> presented below. <br /> General Comments/Recommendations <br /> 1. In the Report, Shell concludes that the GWE is ineffective due to the low pumping rate, but <br /> recommends continued operation of the GWE. Regional Water Board staff do not concur <br /> with the recommendation for continued operation of the GWE in its current configuration. <br /> Previous site documents indicate that there is a blockage in the system extraction well, <br /> MW-1. Shell must determine whether the system can be optimized, including addressing <br /> the blockage in the extraction well, before concurrence with continued GWE operation can <br />