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�i <br />California Regional Water Quality Control Board <br />Central Valley Region <br />Winston H. Hickox <br />Secretaryfar <br />Environmental <br />Protection <br />14 August 2002 <br />Mr. Jim Lancaster <br />Woolsey Oil, Inc. <br />166 Frank West Circle <br />Stockton, CA 95206 <br />Robert Schneider, Chair <br />Sacramento Main Office <br />Internet Address: http://www.swrcb.ca.gov/—rwgcb5 <br />3443 Routier Road, Suite A, Sacramento, California 95827-3003 <br />Phone (916) 255-3000 • FAX (916) 255-3015 <br />Gray Davis <br />FD) ��L�� �overnor <br />AUG 15 2002 <br />ENPERMITH <br />%SERMES <br />MONITORING AND REPORTING PROGRAM NO. R5-2002-0827, WOOLSEY OIL INC., 930 <br />VICTOR ROAD, LODI, SAN JOAQUIN COUNTY, CA <br />Enclosed is Monitoring and Reporting Program (MRP) No. R5-2002-0827. Ground Zero Analysis, Inc. <br />(GZA) provided comments to the draft MRP on your behalf in the Groundwater Monitoring and <br />Sampling Report, Third Quarter 2002 — MRP No. 5-01-841, Woolsey Oil Inc., 930 Victor Road, Lodi, <br />San Joaquin County, CA (Report), dated 30 July 2002. The comments requested removing volatile <br />organic compounds (VOCs) from the sampling program, decreasing the frequency of sampling of MW -7 <br />to semi-annual, decreasing the frequency for reporting to semi-annual, and reducing the total petroleum <br />hydrocarbons, as diesel (TPH-d) sampling to only MW -6. We have incorporated some of the requested <br />changes in MRP No. R5-2002-0827 as discussed below. <br />We concur with the request to remove VOCs from the sampling program, with the exception of <br />MW -6. VOCs (1,2-dichloroethane) were detected in MW -6 groundwater at concentrations that <br />exceeded the Regional Board Water Quality Objectives in November 2001. VOCs will be monitored at <br />MW -6 for four additional quarters, to determine whether VOCs are the result of a seasonal trend <br />previously reported for fuel constituents. The same analytical method (EPA Method 8260B) can be <br />utilized for VOCs and fuel oxygenate analyses. Therefore, the laboratory can evaluate whether VOCs <br />are present during the fuel oxygenate analysis. Future reports will include all VOCs by well, if present. <br />If no VOCs are observed in fuel oxygenate chromatographs at the method detection limits required by <br />the MRP, then the reports should state that VOCs were not detected in groundwater. <br />2. We concur with the request for semi-annual monitoring of MW -7 for all constituents, except fuel <br />oxygenates, including MtBE. The MtBE concentration in MW -7 increased by an order of magnitude <br />between October 2001 and April 2002. MW -7 continues to report the highest levels of MtBE. MtBE <br />will be monitored quarterly at MW -7. <br />3. We concur with the request to remove TPH-d sampling from all wells, with the exception of MW -6. <br />TPH-d was reported at MW -6 (360 µg/L) in January 2002. If the TPH-d results for MW -6 remain non - <br />California Environmental Protection Agency <br />CGS Recycled Paper <br />