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3 STATE OF CALIFORNIA J PETE WILSON. Governor <br /> CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD-- <br /> ; CENTRAL <br /> OARD— <br /> CENTRAL VALLEY REGION,,,/#* <br /> 3443 ROUTIER ROAC), SUITE A <br /> SACRAMENTO. CA 95827-3398 <br /> PHONE: 1916) 361-5600 <br /> FAX: (916) 361-5686 <br /> 11, X <br /> 20 July 1992 RECENt <br /> J 0 L 2 3 1992 <br /> E-NVIRONMENTAL HEALTH <br /> Mr. Jerry Moore I PERM IT/50Y!qtt� <br /> Moore Petroleum, Inc. <br /> P.O. Box 67 <br /> -5304--"—'-� <br /> Banta*- i�—C A`9 <br /> APPLICATION FOR NPDES PERMIT, FRANK'S EXXON #2, 1399 E. YOSEMITE AVE. , <br /> MANTECA, SAN JOAQUIN COUNTY <br /> I have reviewed the file for your site including the application for a <br /> National Pollutant Discharge Elimination System (NPDES) Permit, dated 26 <br /> December 1991, and the "Final Remediation Plan" (FRP) , dated 12 May 1992, both <br /> prepared by your consultant, Aegis Environmental .1 My review concerns the <br /> appropriateness of the proposed treatment system.1 Wayne Pierson's unit, also <br /> of this office, reviews applications for completeness and prepares NPDES <br /> Permits. <br /> I do not object to the proposed treatment systems, in concept, which consist <br /> of vapor extraction and treatment by internal combustion engine, and ground <br /> water extraction, treatment by spray aeration, with discharge to the storm <br /> drain. However, the FRP lacked the following; <br /> a. A map showing water supply wells within feet; <br /> b. A diagram showing the extent of known ground water contamination; <br /> C. Cross sections showing soil stratigraphy and soil contamination; <br /> d. An estimate, showing the calculations; of the radius of influence <br /> of the­ground water-ex.traction.wel.1 ; <br /> e. Aldi`scuss-�ifon-;f the --effects- <br /> of the ground water extraction and <br /> treatment system on ground water and the plume; and <br /> f. A contingency plan for system failures. <br /> In addition, on page 7 of the FRP, your consultant listed cleanup levels for <br /> benzene, toluene, ethylbenzene, and total xylenes in ground water. Regional <br /> Board policy, as laid out in our Basin Plan, is to require remediation systems <br /> to achieve no detectable contamination in soil and ground water and discharge <br /> limits for treated ground water are set at laboratory detection limits. <br />