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STATE OF CALIFORNIA PETE WILSON. Governor <br /> CALIFORNIA REGIONAL WATER QUALITY CON 'ROL BOARD— 00"CENTRAL VALLEY REGION3443 ROUTIER ROAD, SUITE ASACRAMENTO, CA 95827-3098 <br /> PHONE: (916) 361-5600 <br /> FAX: (916) 361-5686 <br /> 28 February 1992 � y <br /> MAR 3 1992 <br /> ENVIRONMENTAL HEALTH <br /> Mr. Fred Proby PERMIT/SERVICES <br /> Time Oil Company <br /> 2737 West Commodore Way <br /> Seattle, WA 98199 <br /> REVISED WORK PLAN AND TIME SCHEDULE FOR THE PORT OF STOCKTON FUEL TERMINAL, <br /> SAN JOAQUIN COUNTY, CASE NO. 3020 <br /> We are in receipt of your 10 February 1992 letter which responds to our <br /> inquiry regarding the status of Santa Fe Pacific Pipelines (SFPP) Partners <br /> with the Technical Committee (TC) , the TC's formal agreement, the free product <br /> recovery system, and the status of individual site investigations and the <br /> entire fuel terminal . Our comments on your response to each item are <br /> presented below. <br /> 1 . Status of Santa Fe Pacific Pipeline (SFPP) Partners. We have received a <br /> response from SFPP regarding its status with the TC. We will respond to <br /> SFPP's letter separately. <br /> 2. Formal Agreement. One of the findings in the TC's formal agreement states <br /> in part: <br /> "Whereas the California Regional Water Quality Control Board for <br /> the Central Valley Region !(the Board) is concerned and alleges <br /> that ground water in the a ea of the site may be contaminated with <br /> petroleum products; " <br /> The above finding is inaccura a because we not only allege but also <br /> unequivocally state that there is petroleum hydrocarbon contamination in <br /> the soil and ground water at the Stockton fuel terminal . This fact is <br /> borne out by copious data that show there is soil and ground water <br /> contamination and free product at the fuel terminal . <br /> 3. Interim Free Product Recovery System. We are concerned that the interim <br /> free product recovery systemas not implemented in spite of our approval <br /> of the system on 17 September 1990. Attachment 1 shows the actions <br /> required in the draft Cleanup and Abatement Order (C&A) and the number of <br /> months allowed to complete each action. We mailed you a copy of the draft <br /> C&A on 18 January 1989. In May 1989, we agreed not to issue the C&A if the <br /> deadlines were met. These deadlines as counted from 1 May 1989 also are <br /> shown in parentheses in Attachment 1. Furthermore, our letter of 3 May <br /> 1989 specified a deadline of 1 August 1989. It has been more than two <br /> years since that date. An alternative system should have been used when <br /> operation of a vacuum truck became difficult. Further delay on this matter <br /> will not be tolerated. <br />