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.,� California Relonal Water Quality Control Board <br /> Central Valley Region <br /> Robert Schneider,Chair <br /> Terry Tamminen Arnold Schwarzenegger <br /> Secretary for Sacramento Main Office Governor <br /> Environmental Internet Address: http://w ,sw cb.ca.gov/mgcb5 <br /> Protection 11020 Sun Center Drive#200 Rancho Cordova,CA 95670-611 D <br /> Phone(916)464-3291 Fax(916)464-4797 ___j E J <br /> 15 September 2004 SEP 1 6 2004 <br /> ENVIRONMtM i NL lU i1 <br /> Mr. Jeff Goold PERMIT/SERW- S <br /> Shell OPUS <br /> 2555 - 13th Ave SW <br /> Seattle, WA 98134 <br /> REVIEW OF REPORTS, SHELL OIL PRODUCTS US,BULK FUEL TERMINAL;3515 NAVY <br /> DRIVE, STOCKTON, SAN JOAQUIN COUNTY <br /> Staff of the Central Valley Regional Water Quality Control Board(Regional Board) reviewed the <br /> following reports submitted by The RETEC Group, Inc. on behalf of Shell Oil Products US (Shell) for <br /> the bulk fuel facility at 3515 Navy Drive in Stockton(site): <br /> • 8 July 2004 Feasibility Study Work Plan—Revision I (Revised FS Work Plan); <br /> • 26 July 2004 Work Plan for Further Downgradient Delineation (Delineation Work Plan); and <br /> • 30 July 2004 Second Quarter Monitoring Report-2004 (QMR). <br /> The Revised FS Work Plan responds to comments in Regional Board staff s 21 May 2004 letter which <br /> provided comments on the 13 May 2004 Feasibility Study Work Plan. The Delineation Work Plan <br /> proposes to collect grab groundwater samples from up to eight borings using temporary casings. Based <br /> on the grab groundwater sampling results, Shell will install up to three monitoring wells after receiving <br /> concurrence from Regional Board staff. The QMR discusses the groundwater monitoring activities <br /> conducted in May. <br /> We have the following comments on the Revised FS Work Plan and the Delineation Work Plan: <br /> 1. The Revised FS Work Plan proposes Oxygen Releasing Compound (ORC®) injections. Shell <br /> must submit a work plan proposing the ORCO injections for Regional Board staff concurrence. <br /> 2. It is unclear whether the Revised FS Work Plan is proposing both peroxide and permanganate <br /> injections and whether the Shell is proposing pilot study injections or bench-scale testing. Shell <br /> must clarify how peroxide and permanganate will be tested for site remediation feasibility. <br /> 3. Figure 1 of the Delineation Work Plan only shows seven proposed locations for the borings with <br /> temporary casings. Therefore, Regional Board staff only concurs with the seven locations <br /> proposed on Figure 1. <br /> California Environmental Protection Agency <br /> �p�Recycled Paper <br />