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- PETE WILSON, Governor <br /> i ATE OF CALIFORNIA- Environmental Pn10 on Agency <br /> ALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD <br /> CENTRAL VALLEY REGION = <br /> � ,i-I I AL HEALT'1f <br /> 3443 Routier Road, Suite A r f - �.?•� . �Fa <br /> Sacramento, CA 95827-3098 RVi'Ccit,. <br /> PHONE: (916) 255-3000 p �j p <br /> FAX: (916) 255-3015 ��1) j'0ii -7) (`M 2; 05 <br /> 1 April 1994 <br /> Mr. Steven Ferrara <br /> Santa Fe Pacific Pipelines, Inc. <br /> 888 South Figueroa Street <br /> Los Angeles, CA 90017 <br /> SANTA FE PACIFIC PIPELINE LEAK, HOLT, SAN JOAQUIN COUNTY <br /> We have reviewed the 15 March 1994 Work Plan for Further Soil and Ground Water Investigation <br /> and Implementation of Interim Remedial Measures provided by your consultant Levine-Fricke (LF). <br /> The work plan proposes to conduct a soil gas survey, construct, develop and sample two new <br /> monitoring wells, resurvey all the monitoring wells, perform well efficiency tests, and hand bail free <br /> product. We have the following comments: <br /> 1. The schedule to conduct the work is completely based upon obtaining access from offsite <br /> property owners. A number of wells, including the extraction wells, already have been <br /> completed on the offsite property. The implementation of remedial action has been put off <br /> for the last four years because SFPP said there were problems with obtaining property <br /> access. Since you have known since our 4 January 1994 letter that further work would be <br /> needed, we see no reason why additional time is needed to gain access. <br /> 2. The work proposed in the work plan is acceptable with the condition that you submit the <br /> results of the soil gas survey and proposed well locations before installing the wells. <br /> 3. The extraction wells at the site have been in place since 1989, and a permit was issued in <br /> July 1993 for the discharge of treated ground water into Trapper Slough. It is crucial that <br /> this extraction system begin operating in order to capture contaminated ground water which <br /> is now migrating (diffusing) upgradient towards the slough. We see no reason why the <br /> extraction system cannot begin operating immediately. <br /> 4. Regular ground water monitoring is needed. Attached is a draft Monitoring and Reporting <br /> Program (MRP) for your review and comment. The MRP requires quarterly monitoring and <br /> sampling of 11 monitoring wells at the site. The quarterly reports shall include tabulations <br /> of the data and a summary of the biweekly free product bailing activities. The reports shall <br /> include figures which show the lateral and vertical extent of the contamination in the <br /> subsurface and the lateral and vertical capture zone (area of influence) produced from the <br /> ground water extraction system. Please submit your comments on the draft MRP by <br /> 27 April 1994 since we plan to issue it by the end of April. <br />