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Mr. Jeff Baker -6 - • 11 March 2009 <br /> Stockton Terminals Technics Committee <br /> pressure to overcome the 110-foot groundwater column overlying the TS/MW-2D <br /> well screen and (2) stoichiometrically demonstrate that twice-monthly 13-Ib oxygen <br /> injections are sufficient to oxidize the petroleum hydrocarbon mass present in the <br /> target zone. <br /> 9. The site is equipped with two ozone generation systems which the STTC claims has <br /> effectively reduced downgradient contaminant concentrations. One generator <br /> reported a 100 percent runtime for the fourth quarter. STTC needs to explain why <br /> use of this technology or the existing system was not presented as an option for the <br /> TS/MW-2D pilot study. <br /> 10.STTC needs to specify the criteria that the STTC will use to determine whether the <br /> frequency of biodegradation parameter data collection should be decreased from <br /> monthly, for the first three months, to quarterly as the test progresses. <br /> 11.Some of the most recalcitrant occurrences of SPH and elevated concentrations of <br /> dissolved phase hydrocarbons occur in monitoring wells TS/MW-2 and TO/T-2, <br /> which is located in the southwest entry area of the Time Oil and Tesoro facilities. <br /> There is no documentation that remediation has been attempted in this area of the <br /> facilities. Regional Water Board staff will be reviewing the remedial site history at <br /> these facilities and, depending on our findings, may request submittal of a work plan <br /> to clean up this area. STTC needs to explain why remediation of this area adjacent <br /> to Navy Drive has not been attempted. <br /> We cannot concur with the Work Plan until the STTC provides adequate responses to <br /> our comments. The STTC may proceed with the communication test as a preliminary <br /> evaluation of the proposed procedure and provide responses to our comments in a <br /> report on the communication test. However, we suggest that the communication test <br /> procedure should also be modified in accordance with our comments. By <br /> 13 April 2009, please provide responses to our comments. <br /> If you have any questions regarding this letter, you may contact me at (916) 464-4811 <br /> or by email at betayior@waterboards.ca.gov. <br /> e, :' -BRIAN TAU , <br /> Engineerieologist <br /> ccMs. ,Margaret Lagorio, San Joaquin County Environmental Health Department, <br /> Stockton <br /> Mr. Jeffrey Wingfield, Port of Stockton <br /> Mr. Mark Chandler, Time Oil Company, Seattle, WA <br /> Mr. Mr. Sergio Morscalchi, Atlantic Richfield Company, San Ramon <br /> Mr. Gary Haeck, Stantec Consulting Corporation., Rancho Cordova <br /> Mr. Mark O'Brien, Environmental Risk Services Corporation, Alamo <br /> Mr. Jeremy Hughes, LFR Inc., Granite Bay <br /> Ms. Vicki Goodenow, NuStar Energy, San Antonio, TX <br />