Laserfiche WebLink
Californiaiegional Water Quality Cor*,rol Board Central Valley Region io <br /> Karl E. Longley,SCD,P.E.,Chair <br /> Linda S.Adams 11020 Sun Center Drive tl200,Rancho Cordova,California 95670.6114 Arnold <br /> Secretaryfor Phone(916)464-3291 •FAX(916)464-4645 Schwarzenegger <br /> Environmental Governor <br /> Protectionhttp://www.waterboards.ca.gov/centralvalley <br /> rL)-*WEDD <br /> 3 October 2008 OCT 0 6 2008 <br /> ENVIRONMEW HEALTH <br /> Mr. Nathan Crum <br /> RMMITJSERVIOES <br /> Valley Pacific Petroleum Services, Inc. <br /> 166 Frank West Circle <br /> Stockton, CA 95206 <br /> FEASIBILITY STUDY/REMEDIAL OPTIONS EVALUATION REPORT ADDENDUM, VALLEY <br /> PACIFIC PETROLEUM SERVICES, 930 VICTOR ROAD, LODI, SAN JOAQUIN COUNTY <br /> Regional Water Quality Control Board, Central Valley Region (Central Valley Water Board) <br /> staff reviewed the 28 August 2008 Feasibility Study/Remedial Options Evaluation Addendum <br /> (Addendum) submitted by Ground Zero Analysis, Inc. (GZA) on behalf of Valley Pacific <br /> Petroleum Services, Inc. (Valley Pacific) for the site at 930 Victor Road in Lodi (Site). <br /> The Addendum was submitted in response to our 31 July 2008 letter directing Valley Pacific to <br /> (1) submit an analysis of high vacuum dual phase extraction (HVDPE) as a remedial option, <br /> (2) submit a sampling and analysis plan to collect four quarters of biodegradation and baseline <br /> groundwater parameters to show whether oxidation is the best attenuation pathway for <br /> reducing contaminant concentrations, and (3) immediately cease discharging and clean up the <br /> aboveground tank (AGT) diesel spill observed during the Regional Board's 3 July 2008 site <br /> visit and describe how site operations have been modified to prevent spills during fuel <br /> transfers. I also spoke with Mr. Greg Stahl of GZA on 9 September 2008 regarding Valley <br /> Pacific's selection of soil vapor extraction and air sparging (SVE/AS) to remediate the <br /> petroleum hydrocarbons in the groundwater and the vadose zone. <br /> Based on the recommendations in the Addendum and my conversation with Mr. Stahl, Valley <br /> Pacific has chosen to eliminate HVDPE based on an estimated cost of $400,000 to operate <br /> the system for about 24 months. This cost is much higher than the estimate of 1250,000 or <br /> more" to operate SVE/AS for the same time span. <br /> The Sampling and Analysis Plan included in the Addendum proposes to supplement the list of <br /> analytes required by MRP No. R5-2002-0827 for MW12, MW2, MW7, MW6R, and MW10 with <br /> laboratory analyses for temperature, pH, oxidation-reduction potential (ORP), and dissolved <br /> oxygen for four quarters. <br /> On 10 September, as you requested in an earlier telephone conversation, I emailed photos <br /> documenting the diesel spill that I observed during my Site visit. On 15 September, your reply <br /> to my email stated that what I observed was a small spill that occurred and was cleaned up at <br /> about the time as my visit. You stated that Valley Pacific would be implementing an <br /> institutional control to contain any future discharges from the diesel AGT fill spout. <br /> Our comments are presented below. <br /> 1. The Central Valley Water Board accepts Valley Pacific's rationale for not selecting HVDPE <br /> as the remedy for this Site. The Addendum concurs with Board staffs request in the <br /> California Environmental Protection Agency <br /> tZa Recycled Paper <br />