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Mr. Nathan Crum - 2 - 31 July 2008 <br /> Valley Pacific Petroleum Services <br /> 2. Despite the benefit of not having to manage large volumes of treated wastewater, as would <br /> be the case with ex-situ treatment technologies, the selection of SVE/AS technology may <br /> not be the most appropriate selection. Valley Pacific has not provided data showing that <br /> oxidation is the best attenuation pathway for reducing contaminant concentrations. In <br /> addition, if the aquifer conditions are strongly reducing, this technology may not have the <br /> capacity to increase DO concentrations to levels that promote degradation. Further <br /> preliminary study to collect groundwater parameters is recommended to evaluate whether <br /> the selection is appropriate and to assess whether a pilot test of this technology is needed <br /> before selecting this alternative. By 1 September 2008, Valley Pacific needs to submit a <br /> sampling and analysis plan to collect four quarters of biodegradation and baseline <br /> groundwater parameters. <br /> 3. During a site visit on 3 July 2008, Regional Water Board staff observed and photographed <br /> an area of moist surface staining inside the gated area at the loading racks. The area <br /> consisted of a stained concrete surface moist with spilled product and partially covered by <br /> hydrophilic rags saturated with red-dyed diesel. The spill appeared to be the product of <br /> multiple repeated minor releases that occur during routine fuel transfers between tankers <br /> and the on-site above ground storage tank (ALTs). All petroleum spills at AGT facilities <br /> greater than threshold quantities (one barrel or 42 gallons) require spill notification in <br /> accordance with the Office of Emergency Services procedures. <br /> In addition to presenting a fire hazard, this area appears to constitute a potential source of <br /> pollution to soil and groundwater. Valley Pacific must immediately cease these spills and <br /> clean up the discharges in this area as part of the initial stage of site cleanup. <br /> We cannot concur with the recommendations of the FS until the issues described above are <br /> resolved. Therefore, by 1 September 2008, Valley Pacific must submit an FS Addendum that <br /> includes (1) a description of how site operations have been modified to cease the fuel <br /> discharges to the ground surface during fuel transfers, (2) an analysis of HVDPE as a remedial <br /> option, and (3) a sampling and analysis plan to collect four quarters of biodegradation and <br /> baseline groundwater parameters. <br /> If you have any questions regarding this letter, you may contact me at (916) 464-4811 or <br /> betaylor@waterboards.ca.gov. <br /> , r <br /> ---------------------------- <br /> BRIAN TAYL . <br /> Engineering Geo, gist <br /> CC" Mr. Harlih Knoll, San Joaquin County Environmental Health Department, Stockton <br /> Mr. Gregory Stahl, Ground Zero Analysis, Inc., Escalon <br /> Mr. Patrick Riddle, Law Offices of Patrick D. Riddle, Acampo <br /> Mr. John Miller, Valley Pacific Petroleum Services, Inc., Stockton <br />