SITE INFORMATION AND CORRESPONDENCE

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Wendy L. Cohen • -2 - • 21 September 1999 Comments to the Draft Revised Monitoring and Reporting Program, the Board is requested to refer to the site as the"SFPP, L.P. (formerly known as Santa Fe Pacific Pipeline Partners), operating partnership for Kinder Morgan Energy Partners, L.P." Since these documents were not submitted on KMEP letterhead, KMEP should clarify these assertions. However, KMEP and its consultants should also be consistent in the usage of the titles of the business entities in question. 2. The treatment system is regulated under the General Order for Discharge of Groundwater from Cleanup of Petroleum Fuel Pollution to Surface Waters, NPDES No. CA0082929. This General Order requires that quarterly monitoring reports include an evaluation of the groundwater cleanup progress, trends, monitoring well analyses and plume containment. The 15 July 1999 report states "for evaluation of the groundwater cleanup progress, trends, monitoring well analyses, and plume containment, please refer,to the separate quarterly groundwater monitoring report as well as other reports submitted under separate cover(s)." This statement is an example of a very relaxed approach toward compliance. This is not only a problem for public review of this report, but also for Board staff because in fact, this information is not contained in the quarterly groundwater monitoring report. 3. Other inadequacies of the NPDES report include a) irregular influent sampling for methyl t-butyl ether(MTBE), b) reporting effluent volume rather than flow, c) no indication of when the system was shut down and for what reasons, and d) missing notes on the condition of the receiving water. These monitoring and reporting deficiencies must be correct in future reports. 4. KMEP proposes in the Comments to the Draft Revised Monitoring and Reporting Program that if oxygenates other than MTBE are not found above detection limits for two quarters,then they will be analyzed on an annual basis only. MTBE will continue to be analyzed on a quarterly basis. This is acceptable, and the final revised MRP has been modified appropriately. 5. In the Comments to the Draft Revised Monitoring and Reporting Program, KMEP points out that there are currently no private water supply wells within 500 feet, so future QMRs will not include sampling of private water supply wells. It is the Discharger's responsibility to monitor future placement of water supply wells near this release site and add these wells to the monitoring program when appropriate. 6. In the Comments to the Draft Revised Monitoring and Reporting Program, KMEP makes the recommendation to discontinue surface water sampling for TPH and BTEX. This is acceptable, and the final revised MRP has been modified appropriately. Appropriate surface water sampling requirements also will be set in the individual NPDES permit for this site. 7. The Results of Surface Water Sampling provides valuable information regarding the extent of impact by MTBE to Trapper Slough. During six of the 11 sampling events conducted since August 1996, detectable concentrations of MTBE ranged from 1.1 ppb to 4.7 ppb. All surface water samples collected on 9 August 1999 from about 720 feet upstream to about 1,200 feet downstream of the discharge point for the on-site groundwater treatment system showed detectable amounts of MTBE. The highest concentration of MTBE found during this study was 3.9 ppb, and levels ranges from 2.0 to 3.9 ppb both upstream and downstream of the discharge. Board staff agrees with the conclusion that the distribution of MTBE in Trapper Slough is not the result of activities at the Holt petroleum release site.