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CalifornWegional Water Quality Coerol Board ow Central Valley Region Robert Schneider,Chair Dan Skopec Acting Secretary Sacramento Main Office Arnold 11020 Sun Center Drive#200,Rancho Cordova,California 956706114 Schwarzenegger Phone(916)4643291•FAX(916)4644645 Governor http://www.waterbouds.ca.gov/centralvalley TO: Brian Newman AqLt. FROM: Pat Leary Supervising Engineer Senior Engineer Underground Storage Tank Unit NPDES, Delta Unit DATE: 19 April 2006 SIGNATURE: ig—(Ltt 1 SUBJECT: NEW WEST STATION NP DES APPLICATION, FLAG CITY; SAN JOAQUIN COUNTY We received a NPDES permit application from Apex Envirotech Inc., on behalf of New West Stations, to discharge treated effluent from a ground water remediation to surface waters in the vicinity of the Flag City development in San Joaquin County. The application was for coverage under the General Order for Discharge to Surface Waters of Groundwater from Cleanup of Petroleum Fuel Pollution, Order No. 5-00-119 (NPDES No. CAG915001). I have completed a cursory review of the application, and find that the information is incomplete as an application for this permit. In addition, based on the submitted materials, I do not believe coverage under this Order is appropriate at this time. Following are my comments: 1. The application indicated that it was for coverage under the NPDES permit, however the application followed the format of Attachment A of Order No. R5-2003-0044, the General Order for Land disposal of Groundwater or Surface Water from Cleanup of Petroleum Pollution, and did not include required information. If a discharge to surface waters is to be considered under the NPDES General Order, all required information listed in Attachment A of that Order, including State Form 200, and USEPA Forms 1 and 2D must be submitted. 2. A filing fee of$1962 was submitted, whereas the filing fee for Order No. 5-00-019 is $5688. 3. The treatment process proposed is not conventionally used, and was not considered in establishing the effluent limitations and requirements of the General Order. The Discharger is proposing to utililze a bioreactor for treatment of the petroleum fuel pollution including TPH, BTEX and oxgenates. In order to enhance the bio-activity in the reactor, nutrients including nitrogen, phosphorus, and potassium are proposed to be added. The concentrations proposed to be used, and the concentration expected in the discharge to surface waters was not provided, but could have reasonable potential to cause or contribute to an exceedance of a water quality objective if discharged to surface waters. The proposal indicates that the effluent from the bioreactor will be polished with granular activated carbon (GAC) units. Evidence needs to be submitted to support that nutrients along with any remaining fuel constituents will be adequately removed in the treatment California Environmental Protection Agency Co Recycled Paper