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California Ronal Water Quality ContrBoard <br /> \� Central Valley Region N. l <br /> Karl E. Longley,ScD, P.E., Chair. ' <br /> Arnold <br /> Linda S.Adams 11020 Sun Center Drive 0200,Rancho Cordova,California 956706114 Schwarzenegger <br /> Sec renin for Phone(916)464-3291 •FAX(916)464-4645 Governor <br /> I'n irmunentul http.//www.waterboards.ca.gov/centralvalley I'�(�C��r, rrr—,D <br /> Prole<von 1I1J^luf(It,V-J- ,1v({Illr��' <br /> 25 November 2009 <br /> DEC - f 2009 <br /> Ms. Carol Campagna ENVIRONMENT HEALTH <br /> PERtaI111T/SERVICES <br /> Shell oil Products US <br /> 20945 South Wilmington Avenue <br /> Carson, CA 90810 <br /> AIR SPARGE/SOIL VAPOR EXTRACTION PILOT TEST REPORT AND FEASIBILITY STUDY <br /> ADDENDUM, SHELL STOCKTON TERMINAL, 3515 NAVY DRIVE, STOCKTON, SAN <br /> JOAQUIN COUNTY <br /> Regional Water Quality Control Board, Central Valley Region (Regional Water Board) staff <br /> reviewed the 30 October 2009 Air Sparge/Soil Vapor Extraction Pilot Test Report and Feasibility <br /> Study Addendum (Addendum) submitted by Conestoga-Rovers and Associates (CRA) on behalf <br /> of Shell Oil Products US (Shell) for the Shell Stockton Terminal at 3515 Navy Drive in Stockton <br /> (Site). <br /> Based on its analysis, Shell recommends implementing Air Sparging/Soil Vapor Extraction <br /> (AS/SVE) using newly installed, deeper AS wells on 30-foot spacing, and horizontal wells <br /> installed at a depth of 4 to 5 feet below ground surface (bgs). Due to decreased groundwater <br /> handling costs, Shell estimates that AS/SVE is more financially and technically feasible in <br /> addition to being more environmentally sustainable than the previously proposed remedial option, <br /> dual phase extraction. Shell proposes to prepare a revised Remedial Action Plan (RAP) upon <br /> Central Valley Board concurrence with this Addendum. <br /> Based on the conclusions in the Addendum, we concur with the proposal to prepare a revised <br /> RAP. However, we are concerned that your proposal to perform vapor extraction from shallow <br /> horizontal wells may present challenges with short-circuiting from the surface. By <br /> 19 January 2010, please submit the revised RAP which much address if short circuiting from the <br /> shallow wells will be problematic and, if so, how it will be addressed. Additionally, Table 3 in the <br /> Addendum tabulates laboratory analytical results, but no copies of the actual laboratory reports <br /> verifying the results are included in the Addendum. By 1 December 2009, please send hard <br /> copies of the laboratory report to complete the Addendum, and also ensure that the laboratory <br /> reports are included when the report is posted on GeoTracker. <br /> If you have any questions regarding this letter, you may contact me at (916) 464-4811 or <br /> betaylor@waterboards.ca.gov. <br /> BRIAN TAYLUK, R.G. <br /> Engineering Geologist <br /> cc list on next page <br /> California Environmental Protection Agency <br /> �a Re cycled Paper <br />