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California*gional Water Quality COW Board E <br /> Central Valley Region ' k. <br /> Katherine Hart,Chair. Arnoldol <br /> Linda S.Adams 11020 Sun Center Drive 9200,Rancho Cordova,California 95670-6114 Schwarzenegger <br /> Secretaryfor Phone(916)464-3291 •FAX(916)4644645 Governor <br /> Environmental http://www.waterboards.ca.gov/centralvalley <br /> Protection REEVED <br /> 16 June 2010 jUN 4 3 LGiG <br /> ENVIRONMENT HEALTH <br /> PERMIT/SERVICES <br /> Mr. Carol Campagna <br /> Shell oil Products US <br /> 20945 South Wilmington Avenue <br /> Carson, CA 90810 <br /> AIR SPARGE WELL AND SOIL VAPOR EXTRACTION WELL INSTALLATION WORK <br /> PLAN, SHELL STOCKTON TERMINAL, 3515 NAW DRIVE, STOCKTON, SAN JOAQUIN <br /> COUNTY <br /> Regional Water Quality Control Board, Central Valley Region (Central Valley Water Board) <br /> staff reviewed the 7 May 2010 Air Sparge Well and Soil Vapor Extraction Well Installation <br /> Plan)Work Plan (Work <br /> on behalf <br /> Shell Oil P oduct US (Shell)lfor Shell's Stockton Conestoga-Rovers ( <br /> Terminal at 3515 NavyDrive)in Stockton f <br /> (Site). <br /> The Work Plan includes a GANTT chart showing that the air sparge/soil vapor extraction <br /> (AS/SVE) wells will be installed between August 2010 and October 2011 and system startup is <br /> expected to occur sometime around January 2012. The Work Plan reduces the total number <br /> of AS wells from 28 to 22 and SVE wells from 15 to 12. <br /> The Work Plan proposes no influent TPHd vapor sampling in 500 milliliter sorbent tubes, as <br /> requested in our 10 February 2010 letter. I left voice mail messages with Ms. Aubrey Cool of <br /> CRA requesting clarification about this matter. On 10 June 2010, by telephone, she stated that <br /> her engineers informed her that there was no reliable way to detect TPHd in effluent vapor. <br /> She stated that the <br /> TPHd. If the lab did inot detect samples <br /> ct TPHd in the effluent submitted <br /> slaboratory analytical <br /> amplecollect othis for s compounds <br /> would be discontinued. <br /> Additionally, on page 2 in Section 2.4, the last sentence reads "No soil samples will be <br /> retained for laboratory analyses from the well boring." However, Section 2.7 on page 3 states <br /> that soil samples will be collected from the 22 AS boreholes and submitted for laboratory <br /> analysis for total petroleum hydrocarbons as gasoline (TPHg), benzene, toluene, <br /> ethylbenzene and xylenes (collectively BTEX), and TPH as diesel (TPHd). Since laboratory <br /> analytical data of soil samples collected during well installation would greatly enhance the <br /> understanding of the distribution of contaminants in each source area, we suspect that Shell <br /> intends to collect and analyze the soil samples. However, clarification is needed to resolve this <br /> discrepancy. <br /> By 2 July 2010, please submit written clarification of Shell's sampling and analysis plan for <br /> (1) TPHd in influent vapors and (2) soil samples retained for laboratory analysis during drilling <br /> of the AS wells. <br /> California Environmental Protection Agency <br /> pia Recycled Paper <br />