SITE INFORMATION AND CORRESPONDENCE

Home Browse Search

Mr Nathan Crum - 2 - 23 May 2008 Valley Pacific Petroleum Services Wells MW-8 and MW-9R recently have contained SPH. Laboratory analysis of SPH samples obtained from these wells and from MW-6R was performed on 29 January 2008. The results showed that the SPH consisted primarily of weathered leaded gasoline and high sulfur diesel. Although some investigative activities have been conducted, the contamination plume has not been adequately delineated. Since 2000, Regional Water Board staff has attempted to work cooperatively with Valley Pacific to complete the investigative work and move forward with remediation. In a 28 November 2007 letter to you, Regional Water Board staff requested a Feasibility Study (FS) by 25 January 2008. When that due date expired, Regional Water Board staff sent a second request on 28 February with a due date of 7 March. Valley Pacific also failed to comply with that due date. During a 14 March site visit, Regional Water Board staff met with Valley Pacific and its environmental consultant, Ground Zero Analysis, Inc. (GZA), to discuss the Site and to reach agreement on how additional work at the Site was to proceed. At that time, Valley Pacific agreed to submit the FS no later than 7 April. On 7 May, Regional Water Board staff contacted Mr. Gregory Stahl of GZA by telephone because Regional Water Board staff had not received the FS. When asked, Mr. Stahl could not confirm whether an FS has been prepared. As of the date of this letter, Regional Water Board staff has not received the FS. Valley Pacific has not completed an evaluation of the feasibility of groundwater cleanup technologies, and no Site cleanup is occurring. In addition, the extent of the unauthorized discharge to groundwater beneath the site remains undefined to the east. These factors lead the Regional Water Board to the conclusion that this site continues to pose an unacceptably high threat to water resources. Pursuant to California Water Code section 13267, Valley Pacific is ordered to submit a Work Plan by 20 June 2008 that proposes a sufficient number of groundwater sampling locations to completely delineate the eastern extent of the plume and a time schedule for conducting the work. In addition, by 18 July 2008, Valley Pacific must submit a FS to select a remedy for separate, sorbed, and dissolved phase CDCs in soil and groundwater. The FS should be prepared in general accordance with the FS outline that Regional Water Board staff provided in our 25 July 2007 letter (copy attached). Additional investigation will be necessary to define the eastern extent of petroleum hydrocarbons in groundwater. Therefore, remedial systems proposed in the FS must have the capacity to be expanded to address the remainder of the plume, once it is defined. If necessary, additional lateral assessment may be implemented simultaneously with cleanup activities to evaluate the efficacy of remedial actions. The requested FS and Work Plan are technical reports. California Water Code section 13267 states, in part: "(b)(1) In conducting an investigation . . ., the regional board may require that any person who has discharged, discharges, or is suspected of having discharged or, discharging, or who proposes to discharge waste within its region . . . shall furnish, under penalty of perjury, technical or monitoring program reports which the regional board requires. The burden, including costs, of these reports shall bear a reasonable relationship to the need for the report and the benefits to be obtained from the reports. In requiring those reports, the regional board shall provide the person with a written explanation with regard to the need for the reports, and shall identify the evidence that supports requiring that person to provide the reports. As described in this letter, Valley Petroleum is subject to this Order pursuant to California Water Code section 13267 because Valley Petroleum is the current owner and operator of the fueling system that suffered an unauthorized release and therefore, Valley Petroleum is