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Stantec • • September 15, 2008 Page 3 of 9 Reference: Response to RWQCB July 30, 2008 Letter with me to get a list of trigger constituent concentrations worked out by 19 September 2008." The RWQCB caseworker did not receive the detailed response sent on June 18, 2008 at 11:02 PM, which responded to the issues raised in the May 30, 2008 letter and the June 5, 2008 meeting. The response presented in abbreviated form what is presented in this letter. The response was erroneously sent to an old email address for Mr. Taylor. This is unfortunate in that it belies the proactive stance taken by STTC in responding to RWQCB requests. The email response also indicated that the information would be presented as a formal letter to the RWQCB in third quarter 2008. Because the requested communication regarding including TBA in the EMP list of compliance analytes was not received by the RWQCB caseworker, the July 30, 2008 letter, requested the following in Comment Number 2: • "By 19 September 2008, STTC needs to submit the proposed list of petroleum hydrocarbons and respective trigger constituent concentrations that will be incorporated into OS monitoring program. The proposal must include a discussion of the TBA data, including adding TBA to the OS monitoring program." The first issue relates to the RWQCB concerns that a formalized list of constituents for the EMP has not been established. The following section addresses this concern. COMPLIANCE ANALYTES FOR THE EMP The historical documents related to the implementation of the EMP outline the basis of the compliance analytes for the trigger wells. The analytes to be evaluated were originally agreed upon in a May 20, 2003 meeting between STTC and the RWQCB to be benzene, toluene, ethylbenzene, xylenes (BTEX), and methyl tertiary butyl ether (MTBE). The meeting was held to discuss RWQCB May 3, 2003 comments on SECOR's April 30, 2003 Corrective Action Plan (CAP). This was prior to installation of the ozone sparge (OS) barrier arrays in September 2004 and prior to the installation of many offsite wells subsequently installed that constitute the current compliance wells for the EMP. At this stage all the compliance wells were conceptually termed trigger wells. In the May 20, 2003 meeting, the RWQCB requested several points of clarification, which were to be presented in an Addendum to the CAP including a contingency plan and "Establishing "trigger boundaries" for individual hydrocarbon constituents for down-gradient A and B zone wells". These compliance analytes were presented in SECOR's June 27, 2003 Response to RWQCB Letter Dated May 9, 2003 And Addendum to Corrective Action Plan Dated April 30, 2003 (Response and Addendum) along with the contingency plan. The RWQCB approved the April 30, 2003 CAP and the June 27, 2003 Response and Addendum in its July 9, 2003 letter entitled Approval of Corrective Action Plan, Stockton Terminals Technical Committee, Port of Stockton, San Joaquin County. Amongst other issues, the June 27 Response and Addendum outlined three categories of compliance wells (remedial observation wells, mid-point observation wells, and trigger wells), which were to be monitored to evaluate the effectiveness of the ozone injection barrier arrays. These are shown below from the 2003 Response and Addendum: IASTTC-Stockton\Reports\Resp to RWQCB July 30,2008\Response to RWQCB July 30,2008 Letter final.doc