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Sent By:�%RWaCB; • 2553015; Apr-13-00 2:02PM; Page 2/3 _2 _ 30 November 1999 Ms- Jill Jefferson 30 gprn, which would result in at least a 10-fold increase in the amount of groundwater it current treats. 2. The addendum to the work plan proposes conducting the capture zone analysis at 10 gpm_and seven gpm. This modification to the initial work plan is acceptable, butt KMEP shall alsKMEP conduct this analysis at the three-gpm treatment rate. Based o the shall propose a remedial strategy that allows for contaminant plume capture. The work plan addendum says that it will take about 10 weeks from Board staff approval to complete this work and submit a report. KMEP must notify me as soon as it knows that it cannot adhere to this schedule. 3. As specified in Appendix B of the General Order for Discharge of Groundwater from Cleanup of Petroleum of Petroleum Fuel Pollution to Surface Waters K1v1EP is required to submit an arnnual Teport of its monitoring and corrective actions. This annual report is due by 30 January 2000, 4. In the 12 May 1999, Combined Annual Groundwater Monitoring Report, Results of Further Investigation and Recommendations for Additional Work, KMEP proposed to install a soil vapor extraction(SVE) network ceonsisting of 15 extraction wells. We approved this work in our 16 July Requirement for Documents Pursuant to Water Code Section 13267. The Status Report for the Installation of a Soil Vapor Extraction and Treatment System submitted on 22 October 1999 says IFR had only rune svE point locations surveyed. This change in the approved work plan was made without Board staff notification. The status report does not detail the SVE design, so it is impossible to determine if the revised design is adequate- LFR also has not completed the SVIF,system installation despite our 16 July approval. In part, the basis for the 16 July enforcement letter was the inability of KIy EP to implement its approved work plans. S. The Deeper Groundwater Investigation and Work Plan for Well Installation, dated 22 October 1999,shows benzene,toluene, ethylbenzene,xylene(BTEX) and total petroleum hydrocarbons in the gasoline range(TPHg)are present to a depth of about 62 feet below ground surface(bgs) at CP-2. The work plan proposes sampling the sand intervals encountered at about 73 feet bgs at CP-2 and 65 feet bgs at CP-4. Subsequent to obtaining the results from this sampling event, three monitoring wells shall be placed near CP-1,2such thatts to the monitor envithe a deepest groundwater impacted by the release of KMEP's petroleum P t. Ibis work plan, as modified in this comment,is approved. The work plan says the it will take about must eight weeks from Board staff approval complete ere to this schedule.submit a re ort. KMEP notify me as soon as it knows that please submit the following documents by the dates shown. 1. By 28 January 2000, a technical report that evaluates the performance of the groundwater interim treatment system and provides optimal pumping rates. 2. By 28 January 2000, a report of findings and a well installation report for the deeper groundwater investigation and well installation.