SITE INFORMATION AND CORRESPONDENCE

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• CLEANUP AND ABATEMENT ORDER NO•007-0709 -5- J. GILBERT MOORE. EILEEN A.MOORE.AND NEW WEST PETROLEUM, INC. NEW WEST PETROLEUM#1003/FLAG CITY SHELL LODI, SAN JOAQUIN COUNTY Regional Board staff letter directed the Dischargers to resume monthly sampling of CSA-31 Well 2 and selected monitoring wells. 18.The Dischargers' consultant has made three application submittals (Report of Waste Discharge, or ROWD) for an NPDES permit since the SJCEHD letter of 16 September 2005, which directed that the Dischargers obtain a permit for the discharge from the groundwater pump and treatment system discharge. The first two ROWDs (24 March 2006 and 26 May 2006) were determined by Regional Board staff to be incomplete, despite Regional Boards staffs' numerous phone conversations with APEX and a directive letter dated 20 April 2006 for the first attempt to complete the NPDES application with the proper forms and data adequate to characterize the discharge. The proposed treatment system included a problematic addition of nitrates and phosphates to "feed the bioreactor', which would require an expensive reverse osmosis treatment to remove the salts introduced into the bioreactor to meet Waste Discharge Requirements (WDRs) for the NPDES permit. 19.The third ROWD for coverage under the NPDES General Permit was submitted on 9 August 2006. The ROWD monitoring information was still missing two laboratory results for constituents found in the proposed receiving waters, White Slough, found under Section 303 (d) List (impaired water bodies of the State) in the Clean Water Act. The approval for coverage under the NPDES General Permit that was issued 1 September 2006 required monitoring of these constituents. The Notice of Applicability was approved based on the Dischargers' removal of the bioreactor, and addition of activated carbon units plus an air stripper to their treatment facility. The threat that the off-site groundwater petroleum plume may pollute the nearby community drinking water well was considered in deciding to allow coverage under the General Order prior to completion of monitoring. Startup of the Interim Pump and Treatment System occurred 6 September 2006 subsequent to a Regional Water Board staff inspection. 20.The Dischargers have not demonstrated that an NPDES permit is the most cost effective method for the long-term discharge of a groundwater pump and treatment remediation, have not shown hydraulic control of the offsite MtBE plume, and have not considered the Regional Board Basin Plan Wastewater Reuse Policy, which would include the discharge to land under WDRs. The issuance of WDRs for a General Permit to discharge to land, with a combination of an onsite infiltration gallery and injection wells may be feasible, more cost effective for the final remediation plan, and would be more compatible with the Regional Board Basin Plan. 21.All of the currently available data indicate that an MtBE release occurred at the Site. Concentrations of MtBE decrease with distance from the Site LISTS and the highest Site MtBE concentration (210,000 pg/L) is in excess of one order of magnitude higher than neighboring Chevron's highest groundwater MtBE concentration (11,000 pg/L) prior to commencement of Chevron's groundwater treatment in 2000. As of 2 August 2006, the maximum MtBE concentration in extraction well EW-4 at the Site declined to 32,000 pg/L. Seventeen weekly 5,000-gallon batch extractions have removed approximately 35 pounds of MtBE, which is over twice the total of 13 pounds