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CONDOR EARTH TECHNOLOGIES INC `l 188 Frank West Circle Suite I j 5 Ah 4: 4�j Stockton CA 95206 l�ii� 2495 �Ar Phone 209 .234.0518 FAX CONDOR f� 30 f\QoN 1 T n S T www,c ndorear h .om May 12, 2005 State Water Resources Control Board UST Cleanup Fund ATTN: Linda Sandbom PO Box 944212 Sacramento, CA 94244-2120 Subject: USTCF Claim # 008449 Payment Summary dated March 7, 2005 Canepa' s Car Wash, 6230 Pacific Avenue, Stockton Condor Project No. 1707C Dear Ms. Sandbom: The purpose of this letter is to respond to your request for explanation regarding City of Stockton connection fees in the Comments section, line 14, of the UST Cleanup Fund Payment Summary dated March 7, 2005 . We would like to thank you for discussing the general NPDES permit as a discharge option for the site. We strive to make the most cost-effective choices for our clients. During our initial planning and preparation for the project, we did not fully anticipate the very high cost of discharging treated groundwater to the municipal sewer system. In addition, we were aware of the generally high cost of discharging via the NPDES permit. We chose to apply for the sanitary sewer discharge permit for these reasons. Treated groundwater from the subject site is currently discharged under a permit through the City of Stockton. The monthly connection fees total 5969 . 16, 'and the monthly commercial sewer charge is $559 . 60; the total feet to discharge treated groundwater through the current City permit is $ 1 ,528 .76 per month. Preliminary research into your inquiry regarding an evaluation ,of groundwater disposal options considering the cost of current sanitary sewer disposal has confirmed our past experience that other options are either not available or not cost effective. Three other disposal options include discharge under the general NPDES permit, land disposal, or transport for off-site treatment. The general NPDES permit for discharge of treated petroleum-contaminated groundwater has not been an option, and if it was available, it would have costs at least similar to sanitary sewer disposal. The permit requires approval of the public agency that owns or operates the storm drain prior to acceptance of the application. To date, the City of Stockton has not allowed any treated groundwater discharge to the storm drains. Consequently, use of the general NPDES permit is likely not an option. Even if the City were to t This total does not include Condor's charges for labor to collect samples, operation, and monitoring, etc., and/or analytical costs, which add approximately $2,000 to $3,000 per month.