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CaliforniaWgional Water Quality Cot#1 Board
<br /> Central Valley Region
<br /> a Karl E.Longley,ScD,P.E.,Chair
<br /> Arnold
<br /> Linda S.Adams Sacramento Main Office Schwarzenegger
<br /> Secretaryfor 11020 Sun Center Drive#200,Rancho Cordova,California 9567w�I ; _z +\ Governor
<br /> Environmental Phone(916)464-3291 •FAX(916)464-4645
<br /> Protection http://www.waterboards.ca.gov/centralvalley Jt j1 * C OQaa
<br /> 14 July 2008 ENVIRONMENT NEZ"
<br /> Mr. JAllen PER.MWSERVtCE
<br /> Jay "3
<br /> Ms. Stephanie Frugal y
<br /> Chevron Environmental Management Company Stone Brothers Management Company
<br /> 6001 Bollinger Canyon Road 1024 W. Robinhood Dr.
<br /> San Ramon, CA 94583 Stockton, CA 95207
<br /> DOCUMENT REVIEW, CLEANUP AND ABATEMENT ORDER(CAO) NO. 5-00-0707, FORMER
<br /> UNOCAL STATION #5098 AT 5606 PACIFIC AVENUE, AND FORMER MONTGOMERY WARDS
<br /> AUTO SERVICE AT 5400 PACIFIC AVENUE, STOCKTON,
<br /> SAN JOAQUIN COUNTY
<br /> I reviewed the Performance Monitoring Plan (Workplan) received 20 June 2008 from ENSR, the
<br /> consultant for Chevron Environmental Management Company (CEMC). The Workplan proposes
<br /> additional analyses and a monthly sampling schedule to track the progress of the upgrades to the Soil
<br /> Vapor Extraction/Air Sparging (SVE/AS) treatment system that were installed between March and July
<br /> of 2008. The objective of the performance monitoring is to demonstrate the effectiveness of the SVE/AS
<br /> upgrades by reducing petroleum hydrocarbons concentrations, and to determine the presence of abiotic
<br /> and biological mechanisms involved in that process. The Scope of Work includes collection of SVE/AS
<br /> operational parameters (vapor flow rates/air flow rates, vacuum/pressure, photo-ionization detector
<br /> concentrations); and on ten select monitoring wells, collect groundwater parameters (dissolved oxygen,
<br /> temperature, specific conductance, and pH), analytical data (petroleum hydrocarbons), monitored
<br /> natural attenuation parameters (total inorganic carbon, nitrate, sulfate, ferrous iron, and sulfide), and
<br /> biodegradation indicators (compound specific isotope analysis, bio-trap®). A report of the activities will
<br /> be presented 60 days after completion of the activities described above.
<br /> I am concerned that the methodology described above, while justifiable and desirable from a technical
<br /> standpoint, are necessary and cost effective as proposed. Since the State of California is reimbursing
<br /> Chevron for costs incurred to cleanup the two sites through the State Water Resources Control Board
<br /> Underground Storage Tanks Commingled Plume Account (CP Account), I strongly recommend that you
<br /> submit the proposed costs and activities to the appropriate CP Account staff for preapproval. Further, I
<br /> believe that preapproval is one of the requirements for commingled account incurred cost
<br /> reimbursement. Please copy me on all submitted documents requesting preapproval prior to initiation
<br /> of proposed activities. You may call me at (916) 464-4615 or email me at ibartonCcDwaterboards.ca.gov
<br /> for questions or additional information.
<br /> v �yt � �r�/I I j ff�
<br /> JAMES L. L. BARYON, P.G.
<br /> Engineering Geologist
<br /> cc: Ms. Judy Reid, SWRCB, UST Cleanup Fund (Commingled Plume Program), Sacramento
<br /> Mr. Mike Infurna, San Joaquin County Environmental Health Division, Stockton
<br /> Ms. Jennifer Johnston, ENSR, 10411 Old Placerville Rd, Ste 210, Sacramento, CA, 95827
<br /> Mr. J. Scott Seyfried, LFR Levine-Fricke, 4190 Douglas Blvd., Ste. 200, Granite Bay, 95746
<br /> Ms. Nicole Gleason, Downey Brand Attnys LLP, 555 Capitol Mall, 10th Floor, Sacramento, 95814
<br /> California Environmental Protection Agency
<br /> pia Recycled Paper
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