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sime 0 MIA IR IS <br /> From: Devra Lewis (dlewis@waterboards.ca.gov] <br /> Sent: Thursday, January 06, 2005 12:32 PM <br /> To: jbaker@tesoropetroleum.com <br /> Cc: aspencer@ashcreekassociates.com; SUPPLPV@bp.com; osborns@kindermorgan.com; <br /> Psime@secor.com; rbenkosky@secor.com; MLagorio@sjcehd.com; <br /> Subject: <br /> rich brandes@stservices.net; mchandler@timeoil.com; Robert_Horvvath@URSCorp.com <br /> 17 December 2004 Regional Board letter re: STTC' <br /> Mr. Baker, <br /> I spoke with Rusty Benkosky and Paula Sime of SECOR today regarding my 17 December 2004 <br /> letter which provided comments on the 25 October 2004 Third Quarter 2004 Site Status, <br /> Groundwater Monitoring, and Remedial Summary Report and the 19 November 2004 Ozone Sparge <br /> Well Installation and System Start-Up Report for the STTC site. Mr. Benkosky <br /> that the contingency plans discussed in the two reports was merely a reiteration of the <br /> contingency plans as a pointed out <br /> letter. Based on this ppIohad by the <br /> First, 2 did review the correspondence <br /> regarding the 9 May 2003 Addendum to Corrective Acional tion I didPlareview April corresponive Officer in a 9 dence 2003 <br /> 20, 2003 <br /> (Addendum) , but admitted that I only reviewed the responses to comments and not the full <br /> Addendum prior to writing the 17 December 2003 letter, which contained the <br /> contingency plans. My second response is that the Regional Board, through experiences <br /> from other sites, has been more stringent with contingency proposed <br /> revise the contingency plans. g Y Plans and that we may need to <br /> r. <br /> the <br /> concerns. The lfirst cconcernyisntthe spikesofdconcentrationsfor <br /> up tothe <br /> anorderof magnitude <br /> over historical concentrations. We clarified that this was included as acontingency plan and my <br /> contingency plan based on SECOR's experiences from other sites so that othersowouthe <br /> ld be <br /> aware of the possibility of the levels the spike could reach, but it is not anticipated <br /> that this large of a spike in concentrat <br /> site because the sparge points are downgions will occur for the ozone system at the STTC <br /> radient of the source areas. Therefore, <br /> Portion of the contingency plan is not changing. this <br /> Secondly, Mr. Benkosky noted that as we discussed in the 20 May 2003 meeting, total <br /> petroleum hydrocarbons (TPH) as gasoline and diesel will not be monitored as part of the <br /> Off-site monitoring of the ozone system due to anomalous detections of these constituents <br /> Off-site in the past. I concurred with this rationale with the clarification that if TPH <br /> as gasoline or diesel are detected off-site and are associated with the STTC site, then <br /> STTC is responsible for delineation and remediation of these pollutants. Therefore, this <br /> portion of the contingency plan is not changing. <br /> The third portion of the discussion is in regards to California Maximum Contaminant Levels <br /> as goals for evaluating the effectiveness of the ozone systems. Although the 9 July 2003 <br /> letter approving the Addendum states the MCLS are sufficient to trigger the contingency <br /> plans, this is no longer appropriate. Being consistent with other sites, the levels for <br /> monitoring the effectiveness of the ozone systems are the water quality goals which <br /> evaluate toxicity, taste, and odor. Based on this, the following limits will be used for <br /> the trigger boundary wells: <br /> benzene - 0.15 micrograms per liter (default of MDL = 0.5 micrograms per liter) California <br /> Public Health Goal in Driving Water - OEHHA (narrative toxicity) ethylbenzene - 29 <br /> micrograms per liter, USEPA Federal Register, Vol 54, No. 97 pp, 22138 and 22139 <br /> (Narrative taste and odor) toluene - 42 micrograms per liter, USEPA Federal Register, Vol <br /> 54, No. 97 pp. 22138 and 22139 (Narrative taste and odor) xylenes - 17 micrograms per <br /> liter, USEPA Federal Register, Vol 54, No. 97 pp, 22138 and 22139 (Narrative taste and <br /> odor) MTBE - 5 micrograms per liter, CCR Title 22, Section 64449, Calif DHS, California <br /> Secondary MCL. <br /> Based on the 1/6/05 phone conversation with Mr. Benkosky and Ms. Sime, the letter due by 7 <br /> January 2005, as requested in the 17 December 2004 letter, is no longer needed. If you <br /> have any questions regarding the information in this email or if this email is not <br /> 1 <br />