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California "egional Water Quality Cop—ol Board , <br /> Central Valley Region , <br /> Karl E. Longlev,ScD,P.E.,Chair <br /> Linda S.Adams 11020 Sun Center Drivc 4200.Rancho Cordova.Caldorma ')S67( 6H 14 Arnold <br /> Secrerari for Phone(9 16)464-3291 FAX(916)464-464 �urSehvcarzenegger <br /> Far olectlronn Bila! eniur <br /> Imp/hvv,��N �.vtaterboards.ca.gov/centralvall� �i" � � <br /> Prorecriai <br /> 31 July 2008 �,►Rr= it � IIlQB <br /> Mr. Nathan Crum ` <br /> Valley Pacific Petroleum Services, Inc. <br /> 166 Frank West Circle <br /> Stockton, CA 95206 <br /> FEASIBILITY STUDY/REMEDIAL OPTIONS EVALUATION REPORT, VALLEY PACIFIC <br /> PETROLEUM SERVICES, 930 VICTOR ROAD, LODI, SAN JOAQUIN COUNTY <br /> Regional Water Quality Control Board, Central Valley Region (Regional Water Board) staff <br /> reviewed the 18 July 2008 Feasibility Study/Remedial Options Evaluation Report (FS) <br /> submitted by Ground Zero Analysis, Inc. (GZA) on behalf of Valley Pacific Petroleum Services, <br /> Inc. (Valley Pacific) for the site at 930 Victor Road in Lodi (Site): <br /> The FS was submitted in response to our 23 May 2008 Order To Submit Technical Reports In <br /> Accordance With Section 13267 Of The California Water Code (13267 Order) which directed <br /> Valley Pacific to submit an FS to select a remedy for separate, sorbed, and dissolved phase <br /> constituents of concern (CDCs) in soil and groundwater by 18 July 2008. <br /> The FS provides an evaluation of the technical and economic feasibility of three remediation <br /> alternatives including Monitored Natural Attenuation (MNA), Soil Vapor Extraction/Air Sparging <br /> (SVE/AS), and In-Situ Chemical Oxidation (ISCO). The FS contains an estimate of the mass <br /> of total petroleum hydrocarbons as gasoline (TPHg), TPH as diesel (TPHd) and benzene in <br /> the vadose zone and below the water table. The vertical extent of contamination is delineated <br /> by monitoring well MW-1 D. Valley Pacific calculated that there is a combined total of about <br /> 21,940 pounds (Ibs) of TPHg, TPHd and benzene sorbed onto the soil mass in the vadose <br /> zone between 10 and 60 feet below ground surface (bgs). The FS estimates that the <br /> combined total mass of the TPHg, benzene, and methyl tertiary butyl ether (MTBE) dissolved <br /> in groundwater is about 93 lbs, and that there are about 20,423 lbs of free product floating on <br /> the groundwater table. <br /> Based on the evaluation, Valley Pacific selected SVE/AS to remediate the contaminants in the <br /> groundwater and vadose zone based on the rationale that SVE/AS would likely enhance the <br /> biodegradation potential of the Site by increasing the dissolved oxygen (DO) levels of the <br /> groundwater. However, the FS states that the selection was made without the benefit of a pilot <br /> study. <br /> Our comments are presented below. <br /> 1 . The remedial option of high-vacuum dual-phase extraction (HVDPE) was notably absent <br /> from the FS. HVDPE technology is uniquely suited to addressing these site conditions <br /> because it is one of the few remedial options with the capacity to simultaneously address <br /> the three phases of petroleum hydrocarbon contamination (solid, liquid and vapor) present <br /> in the subsurface. By 1 September 2008, Valley Pacific needs to submit an addendum to <br /> the FS containing an analysis of HVDPE as a remedial option. <br /> California Environmental Protection Agency, <br /> :'a' herr,led Pop,') <br />