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Sent By;,,RWOCB; 2553015; Apr-13-00 2:02PM; Page 1 <br /> California Regional Water Quality Control Board _: <br /> Central Valley Re-ion <br /> Steven T.Sutler,Chair `' <br /> Gray pais <br /> Winston H.Hickox Governor <br /> SveretaryfOr Sacramento Main Office <br /> Environmental Internet Address= hitp:tlwww.swreb.ea.gOVI—rwgeb5 <br /> Protection 3443(louder Road,Suite A,Sacramento,California 95827-3003 <br /> Phone(916)155-300 I'FAX19M 255-3Q15_....., --. <br /> Post-it*Fax Note 7671 nate �� �� 5►7J <br /> 30 November 1999 to From h <br /> GO.Napt Co. <br /> Phone K Phone <br /> Ms. Jill Jefferson F <br /> Fax# Fax# <br /> Kander Morgan.Energy Partners <br /> 1100 Town and Country Road <br /> Orange, California 92868 <br /> REVIEW OF REPORTS, KINDER MORGAN ENERGY PARTNERS,HOLT RELEASE SITE, <br /> SAN JOAQUIN COUNTY <br /> I have reviewed the following reports prepared by LFR Levine-Fricke(LFR)for Kinder Morgan Energy <br /> Partners' (K,MEP) llolt petroleum release site: <br /> • Addendum to the Work Plan to Conduct a Capture Zone Analysis of the Groundwater Extraction <br /> System,dated 22 October 1999; <br /> • Status Report for the Installation of a Soil Vapor Extraction and Treatment System, dated 22 October <br /> 1999; <br /> • Results of Deeper Groundwater Investigation and Work Plan for Well Installation, dated 22 October <br /> 1999; <br /> • NPDES Monitoring Report Third Quarter 1999, dated 25 October 1999; and <br /> • T'liird Quarter 1999 Groundwater Monitoring Report, dated 28 October 1999. <br /> 1 have the following comments on these documents. <br /> 1 The work plan addendum for a capture zone analysis says that since June 1997,the average <br /> groundwater pumping rate is about seven gallons per minute (gpm) for each of three extraction <br /> ed flow rates from extraction points RW-1,RW-3 and N-17 <br /> points. This rate is based on measur _ <br /> For example, on 14 July 1999 the reported Pumping rates for these wells are six, 10 and <br /> en gprn, <br /> respectively. However,the third quarter NPDES Monitoring Report says, "During p <br /> June 15 through September 29, 1999, 448,069 gallons of groundwater was recovered, <br /> treated, <br /> d, <br /> and discharged in accordance with the permit.." This correlates to 107-day pe andgPm <br /> treatment rate for the three extraction points. K 4:EP weeds to clarify this discrepancy between <br /> 21-gpm extraction rate and a 2.9-gpm treatment rate. In any case, this level of extraction and <br /> treatment is deficient given KMEP's p��must ensure satio an sfactory progress isextraction <br /> made toward fim incl <br /> the design flow rate of 60 gPrri. <br /> remediation. KMEP must also explain why it has not achieved the anticipated extraction rate of <br /> California Environmental Protection Agency <br /> Recycled Paper <br />