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California R g onal Water Quality Control Board <br /> Central Valley Region o <br /> Robert Schneider,Chair r -=r <br /> Terry Tamminen ArncaschwAQenegger <br /> Secretary for Sacramento Main Office - ' Goverjf7 <br /> Environmental Internet Address: http://w .swcb.ca.gov/mgcb5 N = •4 <br /> Protection 11020 Sun Center Drive#200 Rancho Cordova,CA 95670-6114 <br /> Phone(916)464-3291 Fax(916)464-4797 <br /> m <br /> Ty <br /> 21 May 2004 N <br /> Mr. Jeff Goold <br /> Shell OPUS <br /> 2555 - 13th Ave SW <br /> Seattle, WA 98134 <br /> REVIEW OF REPORTS, SHELL OIL PRODUCTS US, BULK FUEL TERMINAL, 3515 <br /> NAVY DRIVE, STOCKTON, SAN JOAQUIN COUNTY <br /> Staff of the Central Valley Regional Water Quality Control Board (Regional Board) has reviewed <br /> the following reports submitted by The RETEC Group, Inc. on behalf of Shell Oil Products US <br /> (Shell) for the bulk fuel facility at 3515 Navy Drive in Stockton (site): <br /> • 1 April 2004 letter(Letter); <br /> • 30 April 2004 First Quarter Monitoring Report—2004(QMR); and <br /> • 13 May 2004 Feasibility Study Work Plan (FS Work Plan). <br /> The Letter adequately responds to comments in Regional Board staffs 5 March 2004 letter <br /> regarding groundwater monitoring report submittals. The QMR discusses the groundwater <br /> monitoring activities conducted in February and states pollution in groundwater is not delineated <br /> to the northwest of monitoring well MW-35. The groundwater extraction(GWE) system has not <br /> operated since December 2003, so there was no update of remedial activities. Based on the <br /> shutdown of the GWE system and Regional Board staff request, Shell submitted the FS Work <br /> Plan. The FS Work Plan proposes remedial goals of source control and containment and to <br /> monitor for natural attenuation parameters. <br /> Although the FS Work Plan states oxygen addition, such as air sparging, chemical oxidation, and <br /> Oxygen Releasing Compound, will be evaluated, it does not describe how. This information <br /> must be included. Remedial goals for the site must include cleanup, not just control and <br /> containment of all pollution emanating from the site. Furthermore, Shell does not discuss which <br /> remedial alternatives will be evaluated to address the fuel oxygenate concentrations in the deeper <br /> water bearing zone. By 2 July 2004, please provide a revised FS Work Plan that includes <br /> revised remedial goals and describes how each remedial alternative will be evaluated in detail <br /> and how the alternatives will address both the shallow and deep water bearing zones. <br /> California Environmental Protection Agency <br /> 0d Recycled Paper <br />