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Mr. Jeffrey Baker -2 - • 17 December 2004 <br /> unacceptable. In a 20 May 2003 meeting,Regional Board staff discussed with STTC <br /> representatives the initial anticipated spike in concentrations, potentially an order of magnitude <br /> increase, for up to one year after the start-up the ozone systems,which was acceptable only if it <br /> did not promote plume migration. However, we did not discuss implementation of a contingency <br /> plan after one year of continued exceedences after the initial "spike period" of more than an order <br /> of magnitude above the highest historical trend, and this is not appropriate. STTC needs to <br /> propose a more appropriate trigger for the contingency plans. <br /> 2. The monitoring of the proposed system observation and trigger wells must evaluate total <br /> petroleum hydrocarbons as gasoline and diesel detections. Although these wells have historic <br /> concentrations of these constituents, STTC can establish an appropriate contingency plan trigger <br /> that considers these historical detections. <br /> 3. The Monitoring Report and Ozone Start-Up Report both refer to California Primary Maximum <br /> Contaminant Levels (MCLs) for the goals to evaluate the effectiveness of the ozone systems. <br /> STTC must use the water quality standards for evaluation of system performance.. <br /> Regional Board staff does not concur with the proposed constituents for monitoring or the trigger for the <br /> contingency plans. By 7 January 2005, submit a letter proposing to include total petroleum <br /> hydrocarbons as gasoline and diesel as part of the ozone system monitoring program and a revised <br /> trigger for the contingency plans. Regional Board staff concurs with the Work Plan. By <br /> 25 March 2005, please submit a well installation report as proposed in the Work Plan. <br /> Regional Board staff in the Spills, Leaks,Investigations, and Cleanup (SLIC) Section are currently <br /> working to include and update SLIC sites in Geotracker. Geotracker is a geographic information system <br /> that provides online access to environmental data. Although Geotracker has been available to the public <br /> for underground storage tank(UST) sites, it is just now including SLIC sites. As of 1 January 2005, SLIC <br /> sites will be required to submit data electronically, as is currently required for UST sites. Therefore, we <br /> request that the members of the STTC review their sites in Geotracker and provide any corrections or <br /> updates to the information. The website address for Geotracker is currently <br /> www.geotracker.swrcb.ca.gov, but this will eventually change to www.geotracker.waterboards.ca.gov. If <br /> you have any questions, you may contact me at(916) 464-4719 or diewis@waterboards.ca.gov. <br /> DEVRA LEWIS <br /> Environmental Scientist <br /> cc: Ms. Margaret Lagorio, San Joaquin County Environmental Health Department, Stockton <br /> Port of Stockton, Office of Environmental and Regulatory Affairs, Stockton <br /> Mr. Paul Supple, Atlantic Richfield Company, Moraga <br /> Mr. Mark Chandler, Time Oil Company, Seattle <br /> Mr. Richard Brandes, ST Services, Martinez <br /> Mr. Steve Osborn, Kinder Morgan Energy Partners, L.P.,Rocklin <br /> Mr. Rusty Benkosky, SECOR International Inc., Sacramento <br /> Mr. Robert Horwath,URS, Oakland <br /> Ms. Amanda Spencer,Hart Crowser, Inc., Lake Oswego, Oregon <br />